In short
- US OFAC - Recent Actions lists secondary sanctions risk under section 1(b) of Executive Order 13224, as amended by Executive Order 13886, for all new SDN entries.
- UORA notes that ASSOCIATION BARAKA is registered as Charity No. W331005557 and ENSEMBLE C MIEUX as Charity No. W423015492.
What happened
OFAC updated its SDN List to include three individuals—Saleem Abdallah Saleem AL-ZAQ, Faouzi BARIKA, and Amel OUALID—and two entities, ASSOCIATION BARAKA and ENSEMBLE C MIEUX. These additions are linked to HAMAS and subject to secondary sanctions risk under section 1(b) of Executive Order 13224, as amended by Executive Order 13886.
ASSOCIATION BARAKA and ENSEMBLE C MIEUX are both registered charities in France, with established dates of 13 Oct 2023 and 01 Jul 2024, respectively. The update specifies their addresses, registration numbers, and links to designated individuals, highlighting their inclusion as [SDGT] entities.
Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886;
In numbers
- W331005557 ASSOCIATION BARAKA Registered Charity No.
What compliance teams should check
- Screen all transactions and relationships for ASSOCIATION BARAKA (Registered Charity No. W331005557) and ENSEMBLE C MIEUX (Registered Charity No. W423015492).
- Update customer due diligence procedures to flag individuals Saleem Abdallah Saleem AL-ZAQ, Faouzi BARIKA, and Amel OUALID as SDGTs linked to HAMAS.
- Review exposure to entities and individuals subject to secondary sanctions risk under section 1(b) of Executive Order 13224, as amended by Executive Order 13886.
Why it matters
This update expands the SDN List with new individuals and entities linked to HAMAS, including registered charities in France. Compliance officers must promptly screen for these names and registration numbers to prevent prohibited transactions and secondary sanctions exposure. The explicit mention of Executive Order 13224, as amended by Executive Order 13886, underscores the legal risk for indirect dealings. Monitoring these additions is crucial for maintaining robust AML/CFT controls and avoiding regulatory penalties.
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