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Date: 22-Jan-2024 Category: Not Applicable State: Union Government Country: Europe

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

Issued by Council of the European Union · Not Applicable

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Executive Summary & Key Takeaways

What it means

  • Council Implementing Regulation (EU) 2024/362 implements Regulation (EU) No 36/2012 concerning restrictive measures in view of the situation in Syria.
  • The regulation adds six individuals and five entities to the list of those subject to restrictive measures as outlined in Annex II to Regulation (EU) No 36/2012.

Key Changes

  • Six individuals have been added to the list of sanctioned persons:
  • Mahmoud al-Dj: A leading businessperson facilitating illicit transactions and benefiting from ties with the Syrian regime. Born on 26.7.1983.
  • Yasser Hussein Ibrahim: An economic advisor to Bashar al-Assad, acting as a front for business activities. Born on 9.4.1983.
  • Bilal al-Naal: Founder and partner of multiple trading and investment companies, member of the Syrian-Russian Business Council and Syrian parliament. Born on 14.4.1975.
  • Fahad Darwish: President of the Joint Syrian-Iranian Chamber of Commerce and owner of multiple businesses. Born in 1955.
  • Mohannad al-Dabbagh: Cousin of Asma al-Assad and co-owner of Takamol LLC, which manages the electronic 'smart card program'. Born on 6.3.1967.
  • Firas al-Akhras: Brother of Asma al-Assad and co-owner of Takamol LLC. Born on 1.3.1978.
  • Five entities have been added to the list of sanctioned entities:
  • Al-Dj Group: A Syrian business entity owned by Mahmoud al-Dj, involved in illicit transactions. Place of registration: Damascus, Syria.
  • Cham Wings: A Syrian airline owned by Muhammad Issam Shammout, allegedly involved in the transfer of mercenaries, arms trade, and money laundering. Place of registration: Damascus, Syria.
  • Freebird Travel Agency: A Syrian business entity owned by Al-Dj Group, acting as an agent for Cham Wings Airlines. Place of registration: Syria, Dubai.
  • Iloma Investment Private JSC: Established in 2023 to take over almost half of the ownership of Damascus airport and acting as a front for the Assad family. Place of registration: Damascus, Syria.
  • Al-Aqila Company: Entered into a joint venture with the Iranian Alborz Insurance Company. Place of registration: Damascus, Syria.

Impact Analysis

Suggested Action Items

  • Cease any business activities with the listed individuals and entities.

Businesses and Individuals

  • Travel restrictions apply to the listed individuals, preventing them from entering the EU.

Syrian Economy

  • The sanctions on entities like Iloma Investment Private JSC aim to prevent the Assad family from profiting from the Syrian economy.

EU Member States

  • Member states may need to update their national regulations to reflect the changes introduced by this regulation.

Key Entities Referenced

Council of the European Union: The body responsible for adopting the regulation. Regulation (EU) No 36/2012: The primary regulation concerning restrictive measures in view of the situation in Syria. Mahmoud al-Dj: A leading businessperson operating in Syria, who owns several companies active in different sectors such as logistics and tourism. Yasser Hussein Ibrahim: An economic advisor to Bashar al-Assad and acts in the economic council run by Asma al-Assad. Bilal al-Naal: A founder and partner of multiple trading and investment companies in Syria. Fahad Darwish: President of the Joint Syrian-Iranian Chamber of Commerce. Mohannad al-Dabbagh: A cousin of Asma al-Assad. He co-owns Takamol LLC Firas al-Akhras: The brother of Asma al-Assad. He is co-owner of the Takamol LLC company Al-Dj Group: A Syrian business entity, owned and managed by Mahmoud al-Dj. Cham Wings: A Syrian business entity which is owned by Muhammad Issam Shammout. Freebird Travel Agency: A Syrian business entity owned and operated by Al-Dj Group, which in turn is owned and managed by Mahmoud al-Dj. Iloma Investment Private JSC: Iloma Investment Private JSC has been established at the beginning of 2023 to take over almost half of the ownership of Damascus airport. Al-Aqila Company: Al-Aqila Company entered into a joint venture with the Iranian Alborz Insurance Company
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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

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