See Full Document Text
Official Journal EN
of the European Union L series
2024/362 22.1.2024
COUNCIL IMPLEMENTING REGULATION (EU) 2024/362
of 22 January 2024
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 2012concerning 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) The Council remains deeply concerned about the situation in Syria. After more than a decade, the conflict in Syria is
far from over and remains a source of suffering and instability.
(3) The Council notes that the Syrian regime continues to pursue its policy of repression and considers it necessary to
maintain and ensure the effectiveness of the restrictive measures in place, by further developing them while
maintaining their targeted and differentiated approach and bearing in mind the humanitarian conditions of the
Syrian population. The Council considers that certain categories of persons and entities are of particular relevance
for the effectiveness of these restrictive measures, given the specific context prevailing in Syria.
(4) In view of the gravity of the situation, the Council considers that six individuals and five entities should be added to
the list of natural and legal persons, entities or bodies subject to restrictive measures set out in Annex II to Regulation
(EU) No 36/2012.
(5) 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.
(1) OJ L 16, 19.1.2012, p. 1.
ELI: http://data.europa.eu/eli/reg_impl/2024/362/oj 1/6EN
OJ L, 22.1.2024
This Regulation shall be binding in its entirety and directly applicable in all Member States.
Done at Brussels, 22 January 2024.
For the Council
The President
J. BORRELL FONTELLES
2/6 ELI: http://data.europa.eu/eli/reg_impl/2024/362/ojELI:
http://data.europa.eu/eli/reg_impl/2024/362/oj
3/6
ANNEX
Annex II to Regulation (EU) No 36/2012 is amended as follows:
(1) the following entries 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
‘353. Mahmoud al-Dj Date of birth: 26.7.1983; Mahmoud al-Dj is a leading businessperson operating in Syria, who owns several 22.1.2024
companies active in different sectors such as logistics and tourism. He facilitates
Place of birth: Tell Rifaat, Aleppo, Syria;
illicit transactions between regime-affiliated persons and entities in Syria and
Nationality: Syrian/Libyan; Eastern Libya, including in relation to narcotics, and the shipments of arms and
mercenaries. His position is enabled through his close ties with the Syrian regime,
Gender: male
from which he and his businesses are benefitting. His activities, on the other hand,
support the Syrian regime and enable it to access illicit revenues. He is therefore
benefiting from, and providing support to, the Syrian regime.
354. Yasser Hussein Ibrahim Date of birth: 9.4.1983; Yasser Ibrahim is an economic advisor to Bashar al-Assad and acts in the economic 22.1.2024
council run by Asma al-Assad. Together with Ali Najib Ibrahim he operates a
Place of birth: Damascus, Syria;
number of shell companies, and acts as a front for business activities of Bashar
Nationality: Syrian; Al-Assad and Asma Al-Assad. Therefore, Yasser Ibrahim is benefiting and
supporting the Syrian regime.
Gender: male
355. Bilal al-Naal Date of birth:14.4.1975; Bilal al-Naal is a founder and partner of multiple trading and investment 22.1.2024
companies in Syria.
(a.k.a. al-Na’al) Place of birth: Damascus, Syria;
He is a member of the Syrian-Russian Business Council making him instrumental
Nationality: Syrian;
in the economic ties between Russia and the Syrian regime. Al-Naal is also a
Gender: male member of the Syrian parliament and former member of the Damascus
governorate council. Therefore, Bilal al-Naal is a leading business person in Syria,
who is in this capacity supporting and benefiting from the Syrian regime. He is
also associated with Fadi Saqr, Cham Holding and Bishr Al-Sabban.
OJ
L,
22.1.2024
EN4/6
ELI:
http://data.europa.eu/eli/reg_impl/2024/362/oj
Name Identifying information Reasons Date of listing
356. Fahad Darwish Date of birth:1955; Fahd Darwish is President of the Joint Syrian-Iranian Chamber of Commerce. In 22.1.2024
addition, Darwish owns and runs multiple businesses in Syria active in different
(a.k.a. Fahd/Fahed) Place of birth: Damascus, Syria;
sectors such as trading and pharmaceuticals.
Nationality: Syrian/Iranian;
Therefore, Darwish is a leading businessperson operating in Syria, who is, in this
Gender: male capacity, supporting and benefitting from the Syrian regime.
357. Mohannad al-Dabbagh Date of birth: 6.3.1967; Mohannad al-Dabbagh is a cousin of Asma al-Assad. He co-owns Takamol LLC, a 22.1.2024
company responsible for managing the electronic “smart card program” used since
Nationality: Syrian/Iranian;
2014 to distribute subsidised food and other products in Syria under the umbrella
Gender: male of the Ministry of Domestic Trade and Consumer Protection. In particular,
Takamol LLC earns a fee for every transaction operated through the smart card.
Mohannad al-Dabbagh is therefore benefitting from and supporting the Syrian
regime.
358. Firas al-Akhras Date of birth: 1.3.1978; Firas al-Akhras is the brother of Asma al-Assad. He is co-owner of the Takamol 22.1.2024’
LLC company responsible for managing the electronic “smart card program” used
Place of birth: London, United Kingdom;
since 2014 to distribute subsidised food and other products in Syria, under the
Nationality: Syrian; umbrella of the Ministry of Domestic Trade and Consumer Protection. In
particular, Takamol LLC earns a fee for every transaction operated through the
Gender: male
smart card.
Firas al-Akhras is therefore benefitting from and supporting the Syrian regime.
EN
OJ
L,
22.1.2024ELI:
http://data.europa.eu/eli/reg_impl/2024/362/oj
5/6
(2) the following entries 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
‘91. Al-Dj Group Place of registration: Damascus, Syria; Al-Dj Group is a Syrian business entity, owned and managed by Mahmoud al-Dj. 22.1.2024
As a holding company it owns and operates the Freebird Travel Agency, an agent
(a.k.a ALDJ) Principal place of business: Syria
for Cham Wings Airlines, which is conducting frequent flights between Syria and
Libya, smuggling mercenaries, and narcotics. Al-Dj Group is further associated
with Al-Tair Company, which is also owned by Mahmoud al-Dj.
Through this scheme of business relations, in which Al-Dj Group plays a central
role, cargo shipping and flights are used for illicit transactions between regime-
affiliated persons and entities in Syria and Eastern Libya, including narcotics.
Al-Dj Group’s activities benefit the Syrian regime and support it in accessing illicit
revenues.
92. Cham Wings Place of registration: Damascus, Syria; Cham Wings Airlines is a Syrian business entity which is owned by Muhammad 22.1.2024
Issam Shammout.
Principal place of business: Damascus, Syria
Also, Cham Wings uses its flights to engage in the transfer of Syrian mercenaries,
arms trade, narcotics trafficking, and money laundering, which supports the
activities of the Syrian regime. As the only private airline in Syria, Cham Wings is
therefore benefiting from, and providing support to the Syrian regime.
93. Freebird Travel Agency Place of registration: Syria, Dubai; The Freebird Travel Agency is a Syrian business entity owned and operated by 22.1.2024
Al-Dj Group, which in turn is owned and managed by Mahmoud al-Dj.
Principal place of business: Damascus, Syria
Freebird serves as principal agent for Cham Wings Airlines. and, thereby benefits
from and provides support to the regime.
OJ
L,
22.1.2024
EN6/6
ELI:
http://data.europa.eu/eli/reg_impl/2024/362/oj
Name Identifying information Reasons Date of listing
94. Iloma Investment Private Place of registration: Damascus, Syria; Iloma Investment Private JSC has been established at the beginning of 2023 to take 22.1.2024
JSC over almost half of the ownership of Damascus airport.
Date of registration: 2023;
(a.k.a. Eloma) Iloma is a front for the Assad family and part of the regime’s efforts to personally
Principal place of business: Damascus, Syria
gain from manipulation of the economy. Therefore, Iloma is supporting and
benefiting from the Syrian regime.
95. Al-Aqila Company Place of registration: Damascus, Syria; Al-Aqila Company entered into a joint venture with the Iranian Alborz Insurance 22.1.2024’
Company, in a move arranged between the two regimes to strengthen Iran’s
(a.k.a. al-Akila/Al-Aqeela Date of registration: 2007;
position in the Syrian economy.
Insurance Company)
Principal place of business: Syria
In the current Syrian business environment, such a joint venture requires the
support of the Syrian Regime. Therefore, the Al-Aqila Company is supporting and
benefitting from the Syrian regime.
EN
OJ
L,
22.1.2024