US Treasury Designates Transnational al-Shabaab Money Laundering Network

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Today, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) imposed sanctions on 16 entities and individuals who compose an expansive business network spanning the Horn of Africa, the United Arab Emirates (UAE), and Cyprus that raises and launders funds for al-Shabaab, a terrorist group affiliated with al-Qa’ida.  Individuals within this network include influential businesspeople in the region that lend financial backing to al-Shabaab, a terrorist group responsible for some of the worst terrorist attacks in East Africa’s modern history.  These attacks have claimed the lives of thousands of innocent civilians.  These individuals and entities are being designated pursuant to Executive Order (E.O.) 13224, as amended, which targets terrorist groups and their enablers.

“The United States is committed to working with regional partners to root out terror financing networks and the entities they abuse to raise and move funds,” said Under Secretary of the Treasury for Terrorism and Financial Intelligence Brian E. Nelson. “Today’s action is part of a multifaceted effort by Treasury to support the Somali government’s economic offensive against al-Shabaab—one of three pillars in their campaign to degrade this deadly terrorist group.”

Al-Shabaab generates over $100 million per year by extorting local businesses and individuals, as well as through the financial support of affiliated businesspeople.  The threat posed by al-Shabaab is not limited to Somalia.  Al-Shabaab’s revenues are disbursed to other al-Qa’ida-supported groups worldwide and help fund al-Qa’ida’s global ambitions to sow discord and undermine good governance.  This action continues Treasury’s efforts to disrupt al-Shabaab’s abuse of the regional financial system and builds on OFAC’s October 2022 designation of a network of al-Shabaab financial facilitators who served as key interlocutors between al-Shabaab and local businesses in Somalia.

AL-SHABAAB MONEY LAUNDERERS IN THE UAE AND EASTERN AFRICA

The network of individuals and entities designated today have been involved in the raising and laundering of millions of dollars through several businesses at the direction and in the interest of al-Shabaab.

Dubai-based Haleel Commodities L.L.C., also known as Haleel Group, is a key financial facilitator for al-Shabaab, which relies on the leaders of Haleel Group, as well as its branches and subsidiaries in Somalia, Kenya, Uganda, and Cyprus to generate and launder funds.  Haleel Group’s subsidiaries in Cyprus include Haleel Finance LTD, Haleel Holdings, and Haleel LTD; the group also has branches in Kenya (Haleel Commodities Limited) and Uganda (Haleel Commodities LTD) and operates as Haleel Electronics in Somalia.

UAE-based Qemat Al Najah General Trading has served as an important money laundering node in the network, and helped  manage and transfer funds for al-Shabaab in connection with Haleel Group.

Kenya-based Faysal Yusuf Dini (Dini) is an al-Shabaab financial facilitator who leverages Haleel Group and some of its leadership to transfer funds on behalf of al-Shabaab.  He also works closely with Kenya-based Mohamed Jumale Ali Awale (Awale) to plan investment projects and money laundering activities.  This includes managing al-Shabaab funds laundered through investment projects and companies, including through Kenya-based Crown Bus Services.  Crown Bus Services has also supported al-Shabaab’s logistical operations.

Hassan Abdirahman Mahamed, a Finland-based Somali citizen, uses money transfer and hawala businesses to support al-Shabaab’s money laundering operations linked to the network of Haleel Group and Qemat Al Najah General Trading.  UAE-based Mohamed Artan Robel is another member of this money laundering network supporting al-Shabaab through the Haleel Group and Qemat Al Najah General Trading.  Abdikarin Farah Mohamed is a Somalia-based key member of this money laundering network.

Farhan Hussein Hayder (Hayder) directs and manages Haleel Group’s branches in Kenya, Uganda, Cyprus, and the UAE, and supports al-Shabaab by generating funds for the group through these businesses.

A notable part of this network is active in Uganda.  Specifically, Abdulkadir Omar Abdullahi (Abdullahi), is associated with Haleel Group’s Uganda branch as its director, along with Omar Sheikh Ali Hilowle (Hilowle) and Hayder.  In his role, Abdullahi has managed and transferred funds for al-Shabaab.

Farhan Hussein Hayder, Mohamed Jumale Ali Awale, Abdulkadir Omar Abdullahi, and Qemat Al Najah General Trading are being designated pursuant to E.O. 13224, as amended, for having acted or purported to act for or on behalf of, directly or indirectly, al-Shabaab, a person whose property is and interest in property are blocked pursuant to E.O. 13224.

Faysal Yusuf Dini, Omar Sheikh Ali Hilowle, Abdikarin Farah Mohamed, and Mohamed Artan Robel are being designated pursuant to E.O. 13224, as amended, for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, al-Shabaab, a person whose property and interest in property are blocked pursuant to E.O. 13224.

Hassan Abdirahman Mahamed is being designated pursuant to E.O. 13224, as amended, for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, Haleel Commodities L.L.C., a person whose property and interest in property are blocked pursuant to E.O. 13224, as amended.

UAE-based Haleel Commodities L.L.C., is being designated pursuant to E.O. 13224, as amended, for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, al-Shabaab, a person whose property and interest in property are blocked pursuant to E.O. 13224.

Cyprus-based Haleel Finance LTD, Haleel Holdings, and Haleel LTD are being designated pursuant to E.O. 13244, as amended, for being owned, controlled, or directed by, directly or indirectly, Haleel Commodities L.L.C., a person whose property and interest in property are proposed to be blacked pursuant to E.O. 13224, as amended.

Kenya-based Haleel Commodities Limited and Crown Bus Services are being designated pursuant to E.O. 13244, as amended, for being owned, controlled, or directed by, directly or indirectly, Mohamed Jumale Ali Awale, a person whose property and interest in property are proposed to be blacked pursuant to E.O. 13224, as amended.

Uganda-based Haleel Commodities LTD is being designated pursuant to E.O. 13244, as amended, for being owned, controlled, or directed by, directly or indirectly, Farhan Hussein Hayder, a person whose property and interest in property are proposed to be blacked pursuant to E.O. 13224, as amended.

SANCTIONS IMPLICATIONS

As a result of today’s action, all property and interests in property of the individuals and entities named above, and of any entities that are owned, directly or indirectly, 50 percent or more by them, individually, or with other blocked persons, that are in the United States or in the possession or control of U.S. persons must be blocked and reported to OFAC.  OFAC’s regulations generally prohibit all dealings by U.S. persons or within the United States (including transactions transiting the United States) that involve any property or interests in property of designated or blocked persons.

Furthermore, engaging in certain transactions with the individuals designated today entails risk of secondary sanctions pursuant to E.O. 13224, as amended.  Pursuant to this authority, OFAC can prohibit or impose strict conditions on the opening or maintaining in the United States of a correspondent account or a payable-through account of a foreign financial institution that knowingly conducted or facilitated any significant transaction on behalf of a Specially Designated Global Terrorist.

The power and integrity of OFAC sanctions derive not only from OFAC’s ability to designate and add persons to the Specially Designated Nationals and Blocked Persons (SDN) List, but also from its willingness to remove persons from the SDN List consistent with the law.  The ultimate goal of sanctions is not to punish, but to bring about a positive change in behavior.  For information concerning the process for seeking removal from an OFAC list, including the SDN List, please refer to OFAC’s Frequently Asked Question 897 here.

For detailed information on the process to submit a request for removal from an OFAC sanctions list, please click here.

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