Date: 2019-01-21Category: Not ApplicableState: Union GovernmentCountry: Europe
Council Implementing Regulation (EU) 2019/85 of 21 January 2019 implementing Regulation (EU) No 36/2012 concerning restrictive measures in view of the situation in Syria
Executive Summary:
Council Implementing Regulation (EU) 2019/85 of 21 January 2019 amends Annex II to Regulation (EU) No 36/2012, adding eleven natural persons and five entities to the list of those subject to restrictive measures in view of the situation in Syria. These additions target prominent businessmen and entities benefiting from and/or supporting the Assad regime, including through involvement in the Marota City development. The regulation entered into force on 21 January 2019.
Key Points / Main Content:
* **Amendment to Annex II of Regulation (EU) No 36/2012:**
* Eleven natural persons are added to Section A ("Persons") of Annex II.
* Five entities are added to Section B ("Entities") of Annex II.
* **Listed Natural Persons:**
* Anas Talas: Leading businessperson with interests in multiple sectors of Syria's economy, benefiting from/supporting the regime through the Talas Group's joint venture in Marota City.
* Nazir Ahmad JamalEddine: Businessperson with investments in the construction industry, benefiting from/supporting the regime through Apex Development's joint venture in Marota City.
* Mazin AlTarazi: Businessperson with investments in construction and aviation, benefiting from/supporting the regime through investments, including in Marota City.
* Samer Foz: CEO of Aman Group, providing financial support to the regime and benefiting from commercial opportunities.
* Khaldoun AlZoubi: Vice President of Aman Holding, linked to Samer Foz, benefiting from/supporting the regime.
* Hussam AlQatirji: CEO of Katerji Group and Member of Parliament, supporting and benefiting from trade deals with the regime.
* Bashar Mohammad Assi: Chairman of the Board of Directors of Aman Damascus, benefiting from/supporting the regime through involvement in Marota City.
* Khaled alZubaidi: Co-owner of Zubaidi and Qalei LLC, benefiting from/supporting the regime through the Grand Town development.
* Hayan Mohammad Nazem Qaddour: Primary Shareholder of Exceed Development and Investment Company, benefiting from/supporting the regime through Marota City development.
* Maen Rizk Allah Haykal: Secondary Shareholder of Exceed Development and Investment Company, benefiting from/supporting the regime through Marota City development.
* Nader Qalei: Majority shareholder of Castle Investment Holding, co-owner of Zubaidi and Qalei LLC, benefiting from/supporting the regime through the Grand Town development.
* **Listed Entities:**
* Rawafed Damascus Private Joint Stock Company: Benefits from/supports the Syrian regime through participation in Marota City.
* Aman Damascus Joint Stock Company: Benefits from/supports the Syrian regime through participation in Marota City.
* Bunyan Damascus Private Joint Stock Company: Benefits from/supports the Syrian regime through participation in Marota City.
* Mirza: Benefits from/supports the Syrian regime through participation in Marota City.
* Developers Private Joint Stock Company: Benefits from/supports the Syrian regime through participation in Marota City.
Impact Analysis:
* **European Union Member States:**
* *Impact:* Required to implement the restrictive measures against the listed individuals and entities.
* *Action Required:* Ensure that all relevant authorities and institutions are aware of the amended list and take appropriate actions to freeze assets and prevent listed individuals and entities from entering or transiting through EU member states.
* **Listed Natural Persons and Entities:**
* *Impact:* Subject to asset freezes and travel bans within the European Union.
* *Action Required:* Ensure compliance with the restrictive measures and seek legal counsel if they believe they have been wrongly targeted.
* **Businesses and Individuals within the European Union:**
* *Impact:* Prohibited from engaging in financial transactions or providing economic resources to the listed individuals and entities.
* *Action Required:* Conduct due diligence to ensure that they are not conducting business with the listed individuals and entities, and report any potential breaches of the sanctions to the relevant authorities.
Key Entities Referenced
European Union: The political and economic union of European countries.
Council Regulation EU No 362012: A Council Regulation concerning restrictive measures in view of the situation in Syria.
Syria: A country in the Middle East which is the subject of restrictive measures in the regulation.
Assad regime: The ruling government in Syria, led by Bashar al-Assad.
Marota City: A regime-backed luxury residential and commercial development in Syria.
Damascus Cham Holding: A company involved in joint ventures for the construction of Marota City.
Aman Group: A Syrian company with interests in multiple sectors of Syria's economy.
Brussels: The city where the regulation was adopted.
L 18 I/4 EN Official Journal of the European Union 21.1.2019
COUNCIL IMPLEMENTING REGULATION (EU) 2019/85
of 21 January 2019
implementing Regulation (EU) No 36/2012 concerning restrictive measures in view of the
situation in Syria
THE COUNCIL OF THE EUROPEAN UNION,
Having regard to the Treaty on the Functioning of the European Union,
Having regard to Council Regulation (EU) No 36/2012 of 18 January 2012 concerning restrictive measures in view of
the situation in Syria and repealing Regulation (EU) No 442/2011 (1), and in particular Article 32(1) thereof,
Having regard to the proposal from the High Representative of the Union for Foreign Affairs and Security Policy,
Whereas:
(1) On 18 January 2012, the Council adopted Regulation (EU) No 36/2012.
(2) In view of the fact that prominent businessmen are making large profits through their ties with the regime and
are helping to finance the regime in return, including through the joint-ventures formed by certain prominent
businessmen and entities with State-backed companies to develop expropriated land, those businessmen and
entities are supporting and benefiting from the Assad regime including through the use of expropriated property.
(3) Furthermore, the expropriation of land by the Assad regime from persons displaced by the conflict in Syria
prevents those persons from being able to return to their homes.
(4) Eleven natural persons and five entities should be added to the list of natural and legal persons, entities or bodies
subject to restrictive measures in Annex II to Regulation (EU) No 36/2012.
(5) Annex II to Regulation (EU) No 36/2012 should therefore be amended accordingly,
HAS ADOPTED THIS REGULATION:
Article 1
Annex II to Regulation (EU) No 36/2012 is amended as set out in the Annex to this Regulation.
Article 2
This Regulation shall enter into force on the date of its publication in the Official Journal of the European Union.
This Regulation shall be binding in its entirety and directly applicable in all Member States.
Done at Brussels, 21 January 2019.
For the Council
The President
F. MOGHERINI
(1) OJ L 16, 19.1.2012, p. 1.21.1.2019 EN Official Journal of the European Union L 18 I/5
ANNEX
1. The following persons are added to the list set out in section A (Persons) of Annex II to Regulation (EU) No 36/2012:
Name Identifying information Reasons Date of listing
‘264. Anas Talas Gender: male Leading businessperson operating in Syria, 21.1.2019
with interests and activities in multiple
(a.k.a. ; Anas Position: Chairman of the Talas
sectors of Syria's economy. Through his
Talous/Tals/Tuls/Tlass) Group
business activities and investments, Anas
Date of birth: 25 March 1971 Talas also benefits from and/or supports
Nationality: Syrian the Syrian regime. In 2018 the Talas
Group, chaired by Anas Talas, entered into
a SYP 23 billion joint venture with
Damascus Cham Holding for the con
struction of Marota City, a regime-backed
luxury residential and commercial devel
opment.
265. Nazir Ahmad Gender: male Leading businessperson operating in Syria 21.1.2019
JamalEddine with significant investments in the con
Position: Cofounder and majority
struction industry, including a controlling
(a.k.a. shareholder of Apex Development
90 % stake in Apex Development and
; and Projects LLC and founder of
Projects LLC, which has entered into
Nazir Ahmad, A'ayan Company for Projects and
a USD 34,8 million joint venture for the
Mohammed JamalEddine) Equipment
construction of Marota City, a regime-
Date of birth: 1962 backed luxury residential and commercial
Nationality: Syrian development. Through his participation in
the Marota City development, Nazir
Ahmad JamalEddine benefits from and/or
supports the Syrian regime.
266. Mazin Al-Tarazi Gender: male Leading businessperson operating in Syria, 21.1.2019
with significant investments in the con
(a.k.a. ; Position: Businessperson
struction and aviation sectors. Through
Mazen al-Tarazi)
Date of birth: September 1962 his investments and activities, Mazin
Nationality: Syrian Al-Tarazi benefits from and/or supports
the Syrian regime. In particular, Al-Tarazi
has concluded a deal with Damascus
Cham Holdings for a USD 320 million in
vestment in the construction of Marota
City, a regime-backed luxury residential
and commercial development; he has also
been granted a licence for a private airline
in Syria.
267. Samer Foz Gender: male Leading businessperson operating in Syria, 21.1.2019
with interests and activities in multiple
(a.k.a. Samir ( ) Foz Position: CEO of Aman Group
sectors of Syria's economy, including a
( )/Fawz; Samer Zuhair
Date of birth: May 1973 regime-backed joint venture involved in
Foz)
Place of birth: Latakia, Syria the development of Marota City, a luxury
residential and commercial development.
Nationalities: Syrian, Turkish
Samer Foz provides financial and other
support to the regime, including funding
the Military Security Shield Forces in Syria
and brokering grain deals. He also benefits
financially from access to commercial op
portunities through the wheat trade and
reconstruction projects as a result of his
links to the regime.L 18 I/6 EN Official Journal of the European Union 21.1.2019
Name Identifying information Reasons Date of listing
Other information:
Executive President of Aman
Group. Subsidiaries: Foz for
Trading, Al-Mohaimen for
Transportation & Contracting.
Aman Group is the private sector
partner in Joint Venture Aman
Damascus JSC with Damascus
Cham Holding, in which Foz is an
individual shareholder. Emmar
Industries is a joint venture
between Aman Group and the
Hamisho Group, in which Foz has
the majority stake and is the
Chairman.
268. Khaldoun Al-Zoubi Gender: male Leading businessperson operating in Syria, 21.1.2019
with interests and activities in multiple
(a.k.a. Khaldoon al-Zu'bi; Position: Vice-president of Aman
sectors of Syria's economy; including his
Khaldoun Zubi) Holding (a.k.a. Aman Group)
roles as Vice President of Aman Holding
Date of birth: 1979 and majority shareholder of Fly Aman air
Nationality: Syrian line. In this capacity, he is linked to Samer
Foz. Aman Holding is represented on the
board of, and holds a majority stake in,
‘Aman Damascus’, a joint venture in the
construction of Marota City, a regime-
backed luxury residential and commer
cial development. Al-Zoubi benefits from
and/or supports the regime through his
position as Vice President of Aman Hold
ing.
269. Hussam Al-Qatirji Gender: male Leading businessperson operating in Syria, 21.1.2019
who is also a Member of Parliament for
(a.k.a. Hussam/Hossam Position: CEO of Katerji Group
Aleppo. Al-Qatirji supports and benefits
Ahmed/Mohammed/ (a.k.a. al-Qatirji Company/Qatirji
from the regime through enabling, and
Muhammad al-Katerji Company/Khatirji Group/Katerji
profiting from, trade deals with the regime
) International Group)
in relation to oil and wheat.
Date of birth: 1982
Place of birth: Raqqa, Syria
Nationality: Syrian
270. Bashar Mohammad Assi Gender: male Leading businessperson operating in Syria, 21.1.2019
with interests and activities in multiple
Position: Chairman of the Board
sectors of Syria's economy, including his
of Directors of ‘Aman Damascus’.
roles as founding partner of Fly Aman air
Founding partner of Fly Aman
line and Chairman of the Board of
Limited Liability airline.
Directors of ‘Aman Damascus’; a joint
Date of birth: 1977 venture involved in the development of
Nationality: Syrian Marota City, a regime-backed luxury
residential and commercial development.
Assi benefits from and/or supports the
regime through his position as Chairman
of the Board of Directors of ‘Aman
Damascus’.21.1.2019 EN Official Journal of the European Union L 18 I/7
Name Identifying information Reasons Date of listing
271. Khaled al-Zubaidi Gender: male Leading businessperson operating in Syria, 21.1.2019
with significant investments in the con
(a.k.a. (Mohammed) Position: Co-owner of Zubaidi and
struction industry, including a 50 % stake
Khaled/Khalid (Bassam) Qalei LLC, Director of Agar
in Zubaidi and Qalei LLC, which is con
(al-) Zubaidi/Zubedi Investment Company, General
structing the luxury tourist city Grand
) Manager of Al Zubaidi company
Town and to which the regime has
and Al Zubaidi & Al Taweet
granted a 45-year agreement in return for
Contracting Company, Director
19-21 % of its revenue. In this capacity he
and Owner of Zubaidi
is linked to Nader Qalei. Khaled al-Zubaidi
Development Company, and
benefits from and/or supports the regime
co-owner of Enjaz Investment
through his business activities, in particu
Company.
lar through this stake in the Grand Town
Nationality: Syrian development.
272. Hayan Mohammad Gender: male Leading businessperson operating in Syria, 21.1.2019
Nazem Qaddour who holds a 67 % stake in Exceed De
Name: Hayan Mohammed Nazem
velopment and Investment, which has
(a.k.a. Hayyan Kaddour Qaddour
entered into a USD 17,7 million joint
bin Mohammed Nazem)
Position: Primary Shareholder of venture for the construction of Marota
Exceed Development and City, a regime-backed luxury residential
Investment Company and commercial development. Through
Date of birth: 1970 his participation in the Marota City devel
opment, Hayan Mohammad Nazem Qad
Nationality: Syrian
dour benefits from and/or supports the
Syrian regime.
273. Maen Rizk Allah Haykal Gender: male Leading businessperson operating in Syria, 21.1.2019
who holds a 33 % stake in Exceed De
(a.k.a. Heikal Bin Position: Secondary Shareholder
velopment and Investment, which has
Rizkallah) of Exceed Development and
entered into a USD 17,7 million joint
Investment Company
venture for the construction of Marota
Nationality: Syrian City, a regime-backed luxury residential
and commercial development. Through
the participation in the Marota City devel
opment, Maen Rizk Allah Haykal benefits
from and/or supports the Syrian regime.
274. Nader Qalei Gender: male Leading businessperson operating in Syria, 21.1.2019’
with significant investments in the con
(a.k.a. Kalai, Kalei) Name: Nader Kalai
struction industry, including a 50 % stake
Date of birth: 9.7.1965 in Zubaidi and Qalei LLC, which is con
Place of birth: Damascus structing the luxury tourist city Grand
Town and to which the regime has
Nationality: Syrian
granted a 45-year agreement in return for
Passport number (including 19-21 % of its revenue. In this capacity,
country that issued and date and he is linked to Khaled al-Zubaidi. Nader
place of issue): Syrian Arab Qalei benefits from and/or supports the
Republic, N 010170320, issue regime through his business activities, in
number: 002-15-L062672, date particular through this stake in the Grand
of issue: 24.5.2015, date of Town development.
expiry: 23.5.2021;
ID number: Syrian Arab Republic,
010-40036453.L 18 I/8 EN Official Journal of the European Union 21.1.2019
Name Identifying information Reasons Date of listing
Position: Majority shareholder of
Castle Investment Holding,
Co-owner of Zubaidi and Qalei
LLC, Chairman of Kalai Industries
Management
Relatives/business associates or
partners/links to listed individuals:
Khaled al-Zubaidi
Address:
Young Avenue, Halifax, Canada
2. The following entities are added to the list set out in section B (Entities) of Annex II to Regulation (EU) No 36/2012:
Name Identifying information Reasons Date of listing
‘72. Rawafed Damascus Address: Damascus, Syria Rawafed Damascus Private Joint Stock 21.1.2019
Private Joint Stock Company is a USD 48,3 million joint ven
Company ture between Damascus Cham Holdings,
Ramak Development and Humanitarian
(a.k.a.
Projects, Al-Ammar LLC, Timeet Trading
Rawafed/Rawafid/Rawafed
LLC (also referred to as Ultimate Trading
(Tributary)
Co. Ltd.), and Wings Private JSC. Rawafed
Damascus Private Joint
supports and/or benefits from the Syrian
Stock Company)
regime, including through its participation
in the regime-backed luxury development
Marota City.
73. Aman Damascus Joint Address: Damascus, Syria Aman Damascus Joint Stock Company is 21.1.2019
Stock Company a USD 18,9 million joint venture between
Damascus Cham Holdings and Aman
(a.k.a. Aman Damascus
Group. Through its participation in the re
JSC)
gime-backed luxury development Marota
City, Aman Damascus supports and/or
benefits from the Syrian regime.
74. Bunyan Damascus Private Address: Damascus, Syria Bunyan Damascus Private Joint Stock 21.1.2019
Joint Stock Company Company is a USD 34,8 million joint ven
ture between Damascus Cham Holdings
(a.k.a. Bunyan Damascus
and Apex Development and Projects LLC
Private JSC)
and Tamayoz LLC. Through its participa
tion in the regime-backed luxury develop
ment Marota City, Bunyan Damascus
Private Joint Stock Company supports
and/or benefits from the Syrian regime.
75. Mirza Address: Damascus, Syria Mirza is a USD 52,7 million joint venture 21.1.2019
between Damascus Cham Holding and
Talas Group. Through its participation in
the regime-backed luxury development
Marota City, Mirza supports and/or bene
fits from the Syrian regime.21.1.2019 EN Official Journal of the European Union L 18 I/9
Name Identifying information Reasons Date of listing
76. Developers Private Joint Address: Damascus, Syria Developers Private Joint Stock Company is 21.1.2019’
Stock Company a USD 17,7 million joint venture between
Damascus Cham Holdings and Exceed
(a.k.a. Developers Private
Development and Investment. Through its
JSC)
participation in the regime-backed luxury
development Marota City, Developers
Private Joint Stock Company supports
and/or benefits from the Syrian regime.