Damascus Updates its “Terrorist List,” Freezing the Assets of 597 Individuals

The Committee for Freezing the Funds of Individuals and Entities (CFFIE) issued Decision No. 3 on July 11, updating the local “terrorism list” first issued in 2017. The updated list mandates the freezing of assets and properties of 597 individuals accused by Damascus of being involved in financing “terrorist” activities or committing money laundering crimes. Some names were added, and others removed.

Out of the 597 individuals listed, 325 are Syrian nationals, 69 are Saudis, including two military officers, and 42 Lebanese, among them political figures such as Saad Hariri and Walid Jumblatt. Additionally, the list includes 32 Kuwaitis, among them a Minister of Justice, an ambassador, and several members of parliament. The list also includes eight Bahrainis, five Qataris, five Yemenis, and also Turkish President Recep Tayyip Erdoğan and former Foreign Minister Ahmet Davutoğlu. Furthermore, 195 entities have been included, comprising associations, organisations, political parties, financial companies, and exchange firms from Syria, the Arab world, and other foreign countries.

Decision No. 3 of 2024 consists of three articles. The first article removes three Syrian names from the previous local terrorism list, the second article adds two new names, and the third article stipulates that the updated list should be published in the Official Gazette.

The CFFIE was formed under the executive instructions of the Anti-Money Laundering Law No. 27 of 2011. It is linked to the Combating Money Laundering and Terrorism Financing Commission (CMLTFC). The CFFIE is chaired by the head of the CMLTFC and includes the First Deputy Governor of the Central Bank of Syria and representatives from the Ministries of Foreign Affairs, Justice, Interior, and Finance. The CFFIE meets every three months or whenever necessary, and its decisions are made unanimously. The CMLTFC operates independently, has judicial powers, and reports to the Central Bank of Syria under Decree No. 33 of 2005, which amended Decree No. 59 of 2003. Its role is to investigate and conduct financial analysis of reports submitted by banks and law enforcement agencies regarding suspicious financial activities.

The recent decision by the CFFIE grants those affected the right to appeal their inclusion on the list before the Council of State. The freezing order on names listed locally will be lifted if they are acquitted and found not guilty of involvement in money laundering or terrorism charges by local courts.

The CFFIE decision No. 3 of 2024, as noted in its preamble, is based on several laws and decisions, including the Prime Minister’s Decision No. 851 of 2014, which outlines the procedures for adopting the local list of terrorist individuals and entities. Additionally, CFFIE Decision No. 3 refers to a previous decision by the same committee, No. 1 of 2017, which included specific individuals and entities in accordance with United Nations Security Council Resolutions 1267 of 1999 and 1373 of 2001. The Syria Report was unable to obtain a copy of Decision No. 1 of 2017.

The decision relies on Security Council Resolutions 1267 and 1373, despite these resolutions being connected to other UN resolutions. For instance, the Security Council established a committee regarding ISIS and Al-Qaeda, and individuals, groups, and entities associated with them, under a series of international resolutions including 1267 (1999), 1989 (2011), and 2253 (2015). Meanwhile, Security Council Resolution 1373 (2001) was passed in response to the 9/11 terrorist attacks, establishing the International Counter-Terrorism Committee (ICTC). One of the tasks of the ICTC is to freeze any funds linked to individuals involved in committing terrorist acts. Resolution 1373 (2001) empowers each UN member state to implement measures to identify and apply freezing actions on individuals or entities that have committed or are suspected of committing terrorist acts.

The Anti-Money Laundering Law No. 27 of 2011, along with its amendments and executive instructions, permits the competent court to confiscate funds related to money laundering and terrorism financing crimes, along with their proceeds and the tools used in these crimes. Law No. 27 of 2011 also allows Syrian courts to enforce foreign court rulings related to the confiscation of assets belonging to convicted individuals.

However, the relationship between the local terrorism list and those set by UN-affiliated international committees remains unclear, especially since the local list includes many Syrians and foreigners whom the Damascus government accuses of “terrorism” due to their political activity against the government.