Mr. Sanctions

Category: Advisories

  • May 1, 2026: OFAC Iran-related Updates, Part 2: General Licenses, FAQs and another Alert… oh, my!

    First, Iran General License W (Authorizing the Wind Down of Transactions Involving Certain Persons Blocked on May 1, 2026):

    iran_glwDownload

    and the new Frequently-Asked Question 1250:

    IRAN SANCTIONS

    1250. Are Iranian digital asset exchanges blocked under OFAC sanctions?

    Answer

    Yes. Executive Order (E.O.) 13599, as implemented by section 560.211(b) of the Iranian Transactions and Sanctions Regulations, 31 CFR part 560 (ITSR), blocks the property and interests in property of Iranian financial institutions. An Iranian financial institution is blocked pursuant to E.O. 13599 regardless of whether it is listed on OFAC’s List of Specially Designated Nationals and Blocked Persons (SDN List). Iranian digital asset exchanges meet the regulatory definition of an “Iranian financial institution” as persons that engage in the business of activities described in section 560.324 of the ITSR.

    All property and interests in property of Iranian digital asset exchanges in the possession or control of U.S. persons, including U.S. financial institutions, or within U.S. jurisdiction, are blocked pursuant to section 560.211 of the ITSR and must be reported to OFAC. See FAQ 160 for additional information regarding the sanctions implications of E.O. 13599. For additional information regarding the application of sanctions to digital assets, please see FAQs 559, 560, 561, 562, 563, 594, 646, and 647, as well as OFAC’s Sanctions Compliance Guidance for the Virtual Currency Industry.

    Date Released

    May 1, 2026

    and a new OFAC Alert (Hormuz News U Can Uz, as Stephen Colbert would say):

    20260501_hormuz_tolls_alertDownload

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  • Burning Question: That OFAC Alert… and what is a Teapot Oil Refinery?

    Let’s start with the defiinition:

    “Teapot” oil refineries are small, privately owned oil refineries primarily based in China’s Shandong province. The nickname comes from their physical appearance — they are called “teapots” because of their compact teapot-like shape, which distinguishes them from the massive facilities run by China’s state-owned oil giants like Sinopec and PetroChina.

    They’re a big deal in the sanctions world for a few reasons.

    First, scale: despite being individually small, they account for about one-quarter of China’s total processing capacity. Collectively they’re a significant chunk of one of the world’s largest oil-refining industries.

    Second, they’re the primary channel for sanctioned oil into China. China’s state-owned refiners are cautious about buying Iranian oil because they do not want to be cut off from the U.S. dollar-based international financial system. The teapots, which mostly serve domestic markets, have been willing to take on that risk. As a result, these unassuming teapots handle approximately 90% of Iran’s total oil exports — a figure consistent with today’s Treasury alert, which notes that China purchases roughly 90 percent of Iran’s oil exports with teapots accounting for the majority.

    Third, their business model depends on buying cheap. Operating on razor-thin margins, they survive by buying cheap crude wherever they can and refining it into fuel for neighboring provinces. Sanctioned oil from Iran (and Russia) comes at steep discounts, which is precisely what makes it attractive.

    The evasion methods are sophisticated. Today’s Treasury alert highlights the use of front companies in Asia and the UAE, intermediary brokers, and a “shadow fleet” of vessels employing tactics like ship-to-ship transfers, falsified documentation, and vessel identity manipulation to disguise the origin of crude shipments.

    OFAC has been actively targeting them. The U.S. Treasury recently sanctioned Hengli Petrochemical (Dalian) Refinery, China’s second-largest independent refinery, for generating hundreds of millions of dollars in revenue for Iran’s military. And today’s alert specifically warns financial institutions to conduct enhanced due diligence on transactions involving China-based refineries, particularly in Shandong Province.

    In short: teapot refineries are the practical infrastructure through which most of Iran’s oil revenue continues to flow, which is why they’ve become a central focus of OFAC’s maximum pressure campaign.

    and here’s a quick and dirty summary of the OFAC Alert issued on Tuesday:

    What it is: OFAC issued a formal warning to banks and financial institutions worldwide about the sanctions risks of doing business with China’s independent “teapot” oil refineries, particularly those in Shandong Province.

    The core problem: China buys about 90% of Iran’s oil exports, and teapot refineries are the primary buyers. Some of these refineries have even used the U.S. financial system for dollar-denominated transactions and to acquire U.S. goods — creating direct U.S. jurisdictional hooks.

    Who’s already been sanctioned: Since the resumption of maximum pressure on Iran, OFAC has designated five teapot refineries by name: Shandong Shouguang Luqing Petrochemical, Shandong Shengxing Chemical, Hebei Xinhai Chemical Group, Shandong Jincheng Petrochemical Group, and Hengli Petrochemical (Dalian) Refinery. Their U.S.-connected property is blocked, and the 50% ownership rule applies to their subsidiaries.

    What OFAC wants banks to do: Three things, essentially — screen for transactions involving designated teapot refineries or others that may be importing Iranian oil; conduct enhanced due diligence on transactions with China-based refineries (especially in Shandong); and communicate sanctions compliance expectations clearly to correspondent banks in China.

    The evasion playbook OFAC is flagging: The alert lays out the specific methods Iran uses to get oil to these refineries undetected. These include front companies in Asia and the UAE that broker shipments and receive payments; middlemen — typically Asia-based companies with vague stated business purposes — acting as brokers between Iranian sellers and teapot buyers; a “shadow fleet” of tankers using deceptive shipping practices like ship-to-ship transfers to obscure cargo origins; blending Iranian oil with oil from other countries and forging documents to relabel it as “Malaysian blend”; and vessel identity manipulation, including reporting data from non-sanctioned or scrapped “zombie vessels” to mask a ship’s true identity.

    The implicit threat: The alert makes clear that OFAC is prepared to deploy secondary sanctions against foreign financial institutions that continue to support Iran’s oil trade. This is a signal to non-U.S. banks — particularly in Asia — that facilitating these transactions carries real consequences, even if the bank has no direct U.S. presence.

    The bottom line for compliance teams: if you’re processing transactions involving Chinese refineries, particularly independent ones in Shandong, OFAC considers that a high-risk activity warranting enhanced scrutiny.

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  • April 28, 2026: OFAC Update, Part 2: New Iran FAQ, and Iran Alert

    On Tuesday, OFAC issued Iran FAQ 1249:

    1249. Are “toll” payments to Iran for safe passage through the Strait of Hormuz authorized?

    Answer

    No. Payments to the Government of Iran or the Islamic Revolutionary Guard Corps (IRGC), directly or indirectly, for safe passage through the Strait of Hormuz would not be authorized for U.S. persons, including U.S. financial institutions, or for U.S.-owned or -controlled foreign entities.

    Such payments also create significant sanctions exposure for non-U.S. persons. Specifically, foreign financial institutions and other non-U.S. persons risk exposure to sanctions for engaging in certain transactions or activities involving designated or otherwise blocked persons. This includes the Government of Iran and the IRGC, which is sanctioned pursuant to several authorities, including nonproliferation and counterterrorism sanctions authorities, and is designated as a Foreign Terrorist Organization.

    Foreign persons that are engaged in certain transactions could also risk sanctions exposure under authorities such as Executive Order 13902, which authorizes sanctions on, among others, persons who have knowingly engaged in certain significant transactions involving determined sectors of the Iranian economy or who have been determined to operate in those sectors, including the financial and petroleum and petrochemical sectors.

    Date Released

    April 28, 2026

    and a new OFAC Alert about teapot oil refineries:

    20260428_teapot_refinery_alertDownload

    and Treasury had an accompanying press release.

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  • Burning Question: The march of time (and minimizing sanctions evasion)

    so, I asked Gemini to build the story of sanctions evasion-related advisory and guidance documents. Its response:

    The latest advisory from March 31, 2026, titled “Guidance on Sham Transactions and Sanctions Evasion,” signals a new frontier in the U.S. government’s efforts to stop illicit actors from hiding their wealth. By reviewing this document and the history of OFAC’s guidance, we can see a clear evolution: sanctions have moved from simple “do not trade with this person” lists to complex “detective manuals” that require companies to spot sophisticated lies.

    Part 1: Summary of Today’s Advisory (March 31, 2026)

    Verified Document: Guidance on Sham Transactions and Sanctions Evasion.

    The core message of this document is that a “paper trail” is no longer enough to prove a transaction is legal. OFAC is warning that blocked individuals—such as sanctioned Russian oligarchs or international drug kingpins—are using “Sham Transactions” to pretend they no longer own their luxury assets (like private jets, yachts, or companies).

    Key “Red Flags” for Sham Transactions:

    • Family Transfers: A sanctioned person “sells” or transfers an asset to a spouse, child, or close associate shortly before or after being sanctioned.
    • Below-Market Deals: Selling a multi-million dollar asset for a tiny fraction of its value, or on terms that don’t make business sense.
    • Invisible Control: The sanctioned person “sells” their private jet but continues to use it for personal travel, meaning they still effectively own it.
    • Unnecessary Complexity: Using layers of shell companies in “tax haven” countries to hide who really benefits from the property.

    Part 2: The Evolution of Sanctions Evasion Guidance

    Over the last decade, OFAC’s guidance has evolved through four distinct “generations.”

    1. The “Who” Era (Foundational / Pre-2019)

    In this era, compliance was relatively simple: don’t do business with anyone on the SDN List (Specially Designated Nationals).

    • The Big Rule (2014): OFAC clarified the “50 Percent Rule,” stating that if a sanctioned person owns 50% or more of any company, that company is also automatically sanctioned—even if its name isn’t on a list.
    • The Evasion: People began splitting ownership into 49% chunks to stay “under the radar.”

    2. The “How” Era (2019: The Framework)

    OFAC realized that companies needed a “playbook” to avoid making mistakes.

    • Key Document: A Framework for OFAC Compliance Commitments (May 2019).
    • Evolution: This established the “5 Pillars” of a good compliance program: management support, risk assessment, internal controls, testing, and training. It told companies: “We won’t just look at who you trade with; we will look at how hard you tried to follow the rules”.

    3. The “Behavioral” Era (2020: Global Maritime Advisory)

    Sanctions evasion moved to the high seas, where bad actors began using “Deceptive Shipping Practices” (DSPs).

    • Key Document: 2020 Global Maritime Advisory.
    • Evolution: Guidance shifted from “Lists” to “Patterns”. Companies were told to watch for ships turning off their GPS (AIS), “spoofing” their location, or transferring cargo between ships in the middle of the ocean (STS transfers) to hide the cargo’s origin.

    4. The “Detective” Era (2023–2026: Shadow Fleets and Sham Deals)

    The current era is defined by the war in Ukraine and the “Russian Oil Price Cap”.

    • The “Shadow Fleet”: Guidance now focuses on “Ghost Ships”—older, poorly maintained vessels with fake insurance used to bypass oil price limits.
    • “Know Your Cargo” (2023): A landmark “Quint-Seal” note (issued by five agencies) told companies they must now verify the cargo, not just the customer.
    • The Latest Step (Today): The 2026 “Sham Transactions” advisory completes the circle. It warns that even when the person looks clean and the ship looks clean, the legal paperwork might be a lie.

    Summary for Non-Experts: How the “Rules of the Game” Changed

    Old Way (2016)New Way (2026)
    “Check the List”: If the name isn’t on the SDN list, you are probably fine.“Check the Vibe”: Even if the name is clean, you must ask: “Does this deal make sense? Why is this ship’s GPS off?”.
    “Simple Ownership”: Just check if a sanctioned person owns 51% of a business.“Ultimate Control”: Check if they secretly control it through a trust, a shell company, or their spouse.
    “Bank Responsibility”: Mostly banks and financial firms had to worry about this.“Industry Responsibility”: Insurers, ship captains, freight forwarders, and luxury goods dealers are now on the front lines.

    Today, OFAC treats every company as a “mini-detective agency.” If you ignore a red flag—like an oligarch suddenly “giving” his yacht to his wife for $1—the government can hold you responsible for “sham” activity.

    So, what do you think? The inclusion of the Framework Document seems a bit of a curveball (certainly I didn’t expect that to pop up), but it seems to follow a certain logic….

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  • March 31, 2026 Sanctions-palooza: OFAC issues guidance on “sham transactions” and sanctions evasion

    20260331_sham_transactions_advisoryDownload

    While this seems pretty basic, for those of us who have been in financial crime compliance for a while, it’s always good to publish this as a reminder for those new to the field or those caught up in the day-to-day who could use a refresher….

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  • Burning Questions: Outside the US, Beyond the letter of regulation

    The prompt:

    Outside the US, what governments issue sanctions-related guidance, advisories, frequently-asked questions and other publications which clarify sanctions legislation and regulation? pease describe the types of publications and their level of detail and specificity for each government, and compare and contrast each country’s set of such documents, Do not limit yourself to English-language texts. And please quote all sources, with URLs when available.

    The response:

    The United States (via OFAC) is often viewed as the “gold standard” for volume and specificity of sanctions guidance. However, owing largely to the complex sanctions landscape post-2022 (Russia/Ukraine), other major economies have rapidly developed their own detailed interpretive infrastructure.

    The following is an analysis of non-US government publications that clarify sanctions legislation, organized by jurisdiction.

    1. United Kingdom: Office of Financial Sanctions Implementation (OFSI)

    Since Brexit, the UK has developed a sanctions infrastructure that rivals the US in complexity and specificity. OFSI is the primary issuing body.

    • Types of Publications:
      • General Guidance: The “Standard Bearer” document. It covers the UK’s definition of ownership and control, licensing processes, and reporting obligations.
      • Sector-Specific Guidance: Detailed guidance for Maritime shipping (oil price cap), Charity/NGOs, and Financial Services.
      • FAQs: Extensive Q&A covering specific regulations (especially the Russia regulations).
      • Blog/Alerts: OFSI uses its blog to publish “Red Alerts” on evasion typologies (e.g., gold, artwork).
      • General Licences: Unlike the US, the UK publishes “General Licences” (GLs) with accompanying explanatory notes that act as effectively binding guidance on what is permitted.
    • Level of Detail & Specificity: High.OFSI provides very specific interpretive guidance. For example, they define “ownership and control” in granular detail (e.g., examining “dominant influence” over a board of directors). They are one of the few bodies outside the US that publishes enforcement actions (monetary penalties) which serve as case-law-like guidance for the industry.
    • Source: OFSI General Guidance and FAQs

    2. European Union: European Commission & Council of the EU

    The EU issues sanctions at the bloc level, but enforcement is done by member states. To ensure uniformity, the Commission has become extremely prolific in issuing interpretive guidance.

    • Types of Publications:
      • Consolidated FAQs: The primary vehicle for EU guidance. Since 2022, the Commission has published hundreds of pages of FAQs specifically on the Russia/Belarus regimes.
      • “Best Practices” Guidelines: High-level documents from the Council of the EU detailing how to implement asset freezes or identifying beneficial ownership.
      • Commission Opinions: Formal legal opinions on how to interpret specific articles of Council Regulations (e.g., whether “transfer” of goods includes transit).
    • Level of Detail & Specificity: High (but Legalistic).EU guidance is often drafted by lawyers for lawyers. It focuses heavily on statutory interpretation (e.g., “Does Article 5aa prohibit X?”). It is less operational than US/UK guidance but provides definitive answers on scope, such as the exact calculation of “50% ownership” and whether it applies to aggregation of shares.
    • Source: European Commission Sanctions FAQs

    3. Australia: Department of Foreign Affairs and Trade (DFAT) & Australian Sanctions Office (ASO)

    Australia has moved toward a user-friendly, toolkit-based approach for the private sector.

    • Types of Publications:
      • Sanctions Compliance Toolkit: A consolidated PDF designed for businesses/universities to build their own compliance programs.
      • Guidance Notes: Thematic papers on specific high-risk sectors (e.g., “Conflict Minerals,” “Maritime Shipping,” “Ransomware”).
      • Advisory Notes: Alerts on specific evasion risks.
    • Level of Detail & Specificity: Medium.Australia’s guidance is excellent on process (how to assess risk, how to apply for a permit) but arguably offers fewer specific interpretive rulings on complex financial scenarios than the UK or EU. It relies heavily on “due diligence” principles rather than prescriptive rules.
    • Source: Australian Sanctions Office Guidance Notes

    4. Canada: Global Affairs Canada (GAC)

    Historically, Canada provided very little guidance beyond the legislative text. This has changed significantly in recent years with the release of formal interpretive documents.

    • Types of Publications:
      • Sanctions Guidance: A formal document released to clarify “Deemed Ownership” (a unique Canadian concept where any entity in a sanctioned country might be “deemed” owned by that state).
      • Thematic Guidance: Specific papers for the Financial Sector and Academic/Research Sector.
      • Sanctions Notices: Updates notifying the public of new listings.
    • Level of Detail & Specificity: Medium-Low.While improving, Canada’s guidance is often broader and less scenario-based. For example, while the definition of “property” is clarified, the specific application to complex financial instruments is often left to the “judgment” of the operator compared to the detailed FAQs of the EU.
    • Source: Global Affairs Canada Sanctions Guidance

    5. Japan: Ministry of Finance (MOF) & METI

    Japan’s guidance differs culturally; it is often integrated into broader trade control and anti-money laundering (AML) frameworks rather than standing alone as “sanctions guidance.”

    • Types of Publications:
      • Trade Control Policy (METI): Detailed lists of controlled items and end-user lists (the “Foreign End User List”) which function as de facto sanctions lists.
      • AML/CFT Guidelines (JFSA/MOF): Guidelines for financial institutions that include sections on asset freezing and screening.
      • Q&A on Foreign Exchange and Foreign Trade Act: Technical Q&A on how to process payments to sanctioned jurisdictions.
    • Level of Detail & Specificity: High (Technical).The guidance is highly technical regarding trade classifications (goods codes) and payment processing permissions. It is less focused on “sanctions evasion typologies” in the Western sense and more on administrative compliance with the Foreign Exchange and Foreign Trade Act.
    • Source: METI Security Export Control Q&A (Japanese/English)

    6. Singapore: Monetary Authority of Singapore (MAS)

    Singapore issues sanctions guidance strictly through its financial regulator, focusing on Financial Institutions (FIs).

    • Types of Publications:
      • MAS Regulations & Notices: Legally binding notices prohibiting transactions with specific countries (e.g., DPRK, Iran, Russia).
      • “Red Flag” Indicators: Publications highlighting suspicious transaction indicators related to proliferation financing or sanctions evasion.
      • FAQs: Specific Q&As for Financial Institutions regarding asset freezing implementation.
    • Level of Detail & Specificity: Medium.The guidance is precise but narrow; it targets FIs almost exclusively. It is highly specific regarding the mechanics of freezing funds but offers less guidance for non-financial corporates (e.g., exporters, manufacturers) compared to the EU or UK.
    • Source: MAS Targeted Financial Sanctions

    Comparative Analysis

    FeatureUK (OFSI)EU (Commission)Australia (ASO)Canada (GAC)Japan (METI/MOF)
    Primary FocusFinancial & Trade interpretationLegal interpretation for Member StatesCompliance process & Risk AssessmentLegislative clarificationTrade control & Admin procedure
    FormatDetailed General Guidance + Blog AlertsMassive Consolidated FAQs“Toolkit” & Thematic NotesThematic WebpagesTechnical Q&A & End-User Lists
    “Control” Defined?Yes (Very detailed tests)Yes (Detailed criteria)Yes (General principles)Yes (“Deemed ownership”)Implicit(subsidiary rules)
    Scenario SpecificityHigh (e.g., Crypto, Maritime)High (e.g., Transit, IP rights)Medium (Sectoral risks)Low-MediumHigh (Product specs)
    ToneCollaborative but strictLegalistic / FormalEducational / PracticalAdvisoryAdministrative / Bureaucratic

    Summary for the User

    • If you need US-style detail: Look to the UK (OFSI) and EU. They are the closest to providing “answers” to specific hypothetical scenarios.
    • If you need to build a program: Australia’s “Toolkit” is one of the best structural guides for how to set up compliance, regardless of jurisdiction.
    • If you are in Trade/Manufacturing: Japan (METI) and EU guidance provide the most detail on controlled goods codes and transit.

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  • December 23, 2025: Amended Syria Tri-Seal Advisory & PAARSS designation updates

    First, from today’s OFAC Notice:

    Today, the U.S. Department of State, the U.S. Department of Commerce, and the U.S. Department of the Treasury’s Office of Foreign Assets Control, have issued an amended Tri-Seal Advisory: Sanctions and Export Controls Relief for Syria, to reflect the repeal of the Caesar Syria Civilian Protection Act of 2019 (Caesar Act). 

    Additionally, there are PAARSS designations which have been updated:

    Amendments:

    PAARSS-related Designations

    [PAARSSR-EO13894] Promoting Accountability for Assad and Regional Stabilization Act of 2019; Executive Order 13894

    The [SYRIA-CAESAR] Program Tag has been removed from the following PAARSS-related designations:

    AL-ADHAM EXCHANGE COMPANY AKAs: AL-ADHAM FOREIGN EXCHANGE Address: May 29th Street, Saroujah, Damascus, Syria; Hisham Al-Atassi Street, Al-Salam Building, Ground Floor, Homs, Syria; Al-Assi Square, Al-Quwwatli Street, Hama, Syria; Al-Quds Street, Tartous, Syria Website: https://aladham-exchange.com.syOrganization Established Date: 16 Feb 2009 Commercial Registry Number: 15691 (Syria)

    AL-ASSAD, Samer Kamal AKAs: AL-ASAD, Samer Address: Syria DOB: 19 May 1973 POB: Qardaha, Syrianationality: Syria Gender: Male Passport: 86368 (Syria) National ID No.: 06200000449 (Syria) Type: Individual

    AL-FADEL EXCHANGE AND MONEY TRANSFER COMPANY AKAs: AL-FADEL EXCHANGE AND INTERNATIONAL TRANSFER COMPANY, AL-FADEL EXCHANGE PRIVATE JOINT STOCK COMPANY, AL-FADEL MONEY TRANSFER AND EXCHANGE PRIVATE JSC Address: Al-Fardous Street, Damascus, Syria; March 8th Street, Al-Sarraj Building, Ground Floor, Lattakia, Syria; Al-Express Street, Al-Farqan Quarter, Aleppo, Syria; Al-Mazza Highway, Damascus, Syria; Sayyida Zeynab, Damascus, Syria; Main Street, Jeremana, Damascus, Syria Website:https://alfadelex.com

    ARFADA PETROLEUM PRIVATE JOINT STOCK COMPANY AKAs: ARFADA PETROLEUM COMPANY JSC, ARVADA PETROLEUM COMPANY JSC Address: Mashroua Dummar, Lot No. 13, Building 12/2, Damascus, SyriaWebsite: https://www.arfada.com/ Organization Established Date: 24 Apr 2018 Organization Type: Support activities for petroleum and natural gas extraction Registration Number: 18394 (Syria)

    BALWI, Fadel Ma’ruf AKAs: AL-BALAWI, Fadel Address: Syria DOB: 01 Jan 1983 POB: Nubl, Syria nationality:Syria Gender: Male Passport: 2251748 (Syria) Type: Individual Linked to: AL-FADEL EXCHANGE AND MONEY TRANSFER COMPANY

    BALWI, Muhammad Ma’ruf AKAs: AL-BALAWI, Muhammad, AL-BALWI, Muhammad Ma’ruf Address: Sayyida Zeynab, Damascus, Syria DOB: 01 Jan 1981 POB: Nubl, Syria nationality: Syria Gender: Male Passport: 1982538 (Syria) Type: Individual Linked to: AL-FADEL EXCHANGE AND MONEY TRANSFER COMPANY

    BALWI, Mut’i Ma’ruf AKAs: AL-BALAWI, Mut’i, BALAWI, Mut’i, BALWI, Maarouf, BALWI, Moutee MaaroufAddress: Syria DOB: 01 Jan 1985 POB: Nubl, Syria nationality: Syria Gender: Male Passport: 2488186 (Syria) Type:Individual Linked to: AL-FADEL EXCHANGE AND MONEY TRANSFER COMPANY

    HAMIEH, Khaldoun Address: Syria DOB: 25 Dec 1973 nationality: Lebanon Gender: Male Passport: LR1939852 (Lebanon) Type: Individual

    JAMALEDDINE, Nazir Ahmad Mohammed AKAs: JAMAL EDDIN, Mohammed Nazer, JAMAL EDDINE, Natheer Ahmed Mohammed, JAMAL EDDINE, Nathier Ahmed Mohammed Address: Damascus, Syria DOB: 02 Jan 1962POB: Damascus, Syria nationality: Syria Gender: Male Passport: N011612445 (Syria) alt. Passport: 002-17-L022286 (Syria) National ID No.: 010-30208342 (Syria) Type: Individual

    LIMITED LIABILITY COMPANY STG LOGISTIC AKAs: OOO STG LOGISTIK, STG STROYTRANSGAZ LOGISTIC, “STG LOGISTIC” Address: 12 Universitetsky Ave, Moscow 119330, Russia; Damascus, SyriaOrganization Established Date: 04 Sep 2009 Tax ID No.: 5027148148 (Russia) Registration Number:1095027004236 (Russia)

    MAYA EXCHANGE COMPANY AKAs: MAYA FOR EXCHANGE AND INTERNATIONAL HAWALAS Address:Ground Floor, Property Number 17/9/2230, Baqi Zadeh Building, Fardus Street, Salhiyah, Damascus, Syria; First Real Estate Zone, Property Number 936, Section 2, Ground Floor, Haju Building, Abd al-Hamid al-Durubi Street, Homs, Syria; Tartus Real Estate Zone, Section 8, Property Number 3881, Revolution Street, Al-Baraniyah, Tartus, Syria; Ground Floor, Second Real Estate Zone, Sections 7-9, Property 2533, Aziziyah Falls, Baghdad Station, Aleppo, SyriaOrganization Type: Other monetary intermediation

    QADDOUR, Khalid AKAs: QADDOUR, Khaled Nasser Address: Yaafour, Damascus, Syria DOB: 23 Apr 1970 POB:Damascus, Syria nationality: Syria Gender: Male National ID No.: 01020097227 (Syria) Type: Individual Linked to:AL-ASSAD, Maher

    RAMAK DEVELOPMENT AND HUMANITARIAN PROJECTS LLC AKAs: RAMAK COMPANY FOR DEVELOPMENT AND HUMANITARIAN PROJECTS LLC Address: Rural Damascus, Syria Organization Established Date: 08 Aug 2011 Organization Type: Real estate activities with own or leased property alt. Organization Type: Construction of buildings

    SALLIZAR SHIPPING SAL Address: 1st Floor, Shuwairi Bldg., Boulevard Saib Salam, al-Masraa, Beirut Corniche, Lebanon Organization Established Date: 12 Apr 2018 Registration Number: 1024992 (Lebanon)

    TAMAYOZ LLC AKAs: EXCELLENCE LIMITED LIABILITY COMPANY Address: Damascus, Syria Organization Type: Real estate activities with own or leased property

    WINGS PRIVATE JSC AKAs: AL-AJNAHA PRIVATE JOINT STOCK COMPANY, WINGS COMPANY, WINGS PRIVATE JOINT STOCK COMPANY Address: Rural Damascus, Syria Organization Type: Real estate activities with own or leased property

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