Our Island Plan

Financial Sanctions: Counter-Terrorism (Domestic)

Thursday, 29 August 2024

This news release is issued to publicise the amendment of two entries under the Counter Terrorism (Domestic) sanctions regime.

The following UK Regulations have effect in the Isle of Man by the Sanctions (Implementation of UK Sanctions) Regulations 2024 ('the Regulations'), which are made under the Sanctions Act 2024:

  • The Counter-Terrorism (Sanctions) (EU Exit) Regulations 2019
  • Counter-Terrorism (International Sanctions) (EU Exit) Regulations 2019

They put in place measures for the purpose of furthering the prevention of terrorism in the Isle of Man (IOM), the United Kingdom or elsewhere and protecting national security interests.

Those persons who are designated under this regime are included on the UK sanctions list.

Types of sanctions applicable under this regime:

  • Asset freeze
  • Trade
  • Immigration
  • Travel ban

On 29 August, the Foreign, Commonwealth and Development Office updated the UK sanctions list. This list provides details of those designated under sanctions legislation.

Amendment

The UK Government has made two variations to the Consolidated List to the following entries under the Counter-Terrorism (Domestic) sanctions regime. These individuals remain subject to an asset freeze and are now also subject to a travel ban.

Deleted information appears in [square brackets]. Additional information appears in italics.

Individuals

  1. AHMAD, Nazem
    DOB: 05/01/1965. POB: Sierra Leone a.k.a: (1) AHMAD, Nazem, Ali (2) AHMAD, Nazem, Saeed (3) AHMAD, Nazim (4) AHMAD, Nazim, Sa'id (5) AHMAD, Nizam, Saed (6) AHMED, Nazem, Said (7) AHMED, Nazem, Saied (8) MUHAMADI, Kariumu  Nationality: (1) Lebanon (2) Belgium Passport Number: (1) EN800609 (2) B0873597 Passport Details: (1) Issuing Country: Belgium. Date of Expiry: 19/09/2023. (2) Issuing Country: Uganda. Date of Expiry: 13 June 2021. Issued under the name Kariumu MUHAMADI. Likely issued by the Ugandan Government in Kampala on 13 June 2011.  Address: (1) Baconia S.A.R.L, Mahfouz Store Street, Pearl Building, GF, Baabda, Lebanon.(2) Mteferraa From Es Semrlnd, Beirut, Lebanon. Other Information: Sanction imposed in addition to an asset freeze: Travel ban. Date travel ban imposed: 29/08/2024. (UK Sanctions List Ref): CTD0002. (UK Statement of Reasons): We have reasonable grounds to suspect that Nazem AHMAD ('AHMAD') is an involved person under reg. 6 of the Counter-Terrorism (Sanctions) (EU Exit) Regulations 2019 on the basis of the following grounds: (1) AHMAD has been associated with an involved person, namely Hizballah; and (2) AHMAD has been involved in terrorist activity by providing financial services, or making available funds or economic resources, for the purposes of terrorism. We have reasonable grounds to suspect that at least the following entities are controlled by AHMAD, and are therefore also subject to the asset freeze on AHMAD: WHITE STAR DMCC (a UAE company), BEXLEY WAY GENERAL TRADING LLC (a UAE company), BEST DIAMOND HOUSE DMCC (a UAE company), SIERRA GEM DIAMONDS COMPANY NV (a Belgium company); PARK VENTURES SAL (a Lebanon company); and THE ARTUAL GALLERY (Beirut, Lebanon). (Gender): Male Listed on: 18/04/2023 UK Sanctions List Date Designated: 18/04/2023 Last Updated: [18/04/2023] 29/08/2024 Group ID: 15887

  2. AYASH, Mustafa
    DOB: 18/09/1992. POB: Gaza, Palestine a.k.a: AYYASH, Mustafa  Nationality: Palestine Passport Number: K1332951 Passport Details: Austrian Passport National Identification Number: 160715450-005  National Identification Details: Austrian National Identity Card Address: Winerstrasse 20, Linz, Austria, 4020. Other Information: Sanction imposed in addition to an asset freeze: Travel ban. Date travel ban imposed: 29/08/2024. (UK Sanctions List Ref): CTD0004. We have reasonable grounds to suspect that at least the following crypto wallets are owned or controlled by AYASH or Gaza Now and are therefore also subject to the asset freeze on AYASH:

    1)    ETH: 0x175d44451403Edf28469dF03A9280c1197ADb92c
    2)    BNB:  0x175d44451403Edf28469dF03A9280c1197ADb92c
    3)    USDT:  TGJVc32ig2u8tQsYMLE7KXHT5NDQroaVNU
    4)    USDT: TXEsK1sEsKjZ1xtHitnyAAoqw3WLdYdRNW
    5)    USDT: TH96tFMn8KGiYSLiwcV3E2UiaJc8jmcbz3
    6)    USDT: TTgcTTNbNuFdbrhvbjMZVrdU5KALyzDaPw
    7)    BNB: 0xE950DC316b836e4EeFb8308bf32Bf7C72a1358FF
    8)    ETH: 0xE950DC316b836e4EeFb8308bf32Bf7C72a1358FF
    9)    ETH: 0x21B8d56BDA776bbE68655A16895afd96F5534feD
    10) BTC: 3Q8H2ZWMtc4R1M3mkmhnTjCoYKTeCFigDP

    (UK Statement of Reasons): We have reasonable (10) grounds to suspect that Mustafa AYASH ('AYASH') is an involved person on the basis that AYASH: 1. Has been involved in terrorist activity by: a. Promoting and encouraging Hamas and Palestinian Islamic Jihad through the organisation Gaza Now; b. Providing financial services for the purposes of terrorism by providing financial services to Gaza Now; and c. Supporting or assisting Gaza Now, a person whom it is reasonable to suspect AYASH knew or believed was involved in promoting or encouraging terrorism; and 2. Is associated with persons who are or have been involved in terrorist activity, namely Gaza Now. We have reasonable grounds to suspect that at least the following entities are controlled by AYASH and are therefore also subject to the asset freeze on AYASH: Gaza Now. (Gender): Male Listed on: 27/03/2024 UK Sanctions List Date Designated: 27/03/2024 Last Updated: [27/03/2024] 29/08/2024 Group ID: 16459

What you must do

If you suspect a person or entity is a match to a person or entity included in the UK Sanctions List, and you hold or otherwise deal with funds or economic resources of that person:

  1. Check whether you hold any information related to if the persons set out in this Notice are in the UK/IOM or intend to travel to the UK/IOM

  2. Check whether you hold any information related to the UK/IOM immigration status for the persons set out in this Notice

  3. If you are a transport carrier you should deny the persons set out in this Notice boarding if travelling to the UK/IOM, including for transit purposes

  4. Check whether you maintain any accounts or hold any funds or economic resources for the persons set out in this Notice and any entities owned or controlled by them

  5. Freeze such accounts, and other funds or economic resources immediately

  6. You must review the information you hold for that person against the UK Sanctions List to ensure you do not have a false positive identification

  7. Do not deal with those assets or make them available to, or for the benefit of the designated person unless:
    • You have a legal exemption
    • You have a licence

  8. You must report the frozen assets to the FIU

If you have a suspicion or knowledge that there has been a breach of sanctions law, or any attempted transactions that you have blocked, report your suspicions to the FIU.

Failure to comply with financial and trade sanctions legislation or to attempting to circumvent its provisions is a criminal offence.

Where a relevant institution has already reported details of accounts, other funds or economic resources held frozen for the designated person, you are not required to report these details again.

Note: determining if a customer is on the UK Sanctions List includes whether any corporate entity is owned or controlled, directly or indirectly, by a person on the UK Sanctions List.

Further guidance on false positives and delistings and what to do can be found in the Financial Sanctions General Guidance page.

Further information

Further details on the UN measures in respect of Counter Terrorism sanctions can be found on the relevant UN Sanctions Committee webpage.

Further information on the sanctions regime related to Counter Terrorism and other sanctions related guidance can be found on the Sanctions and Export Control website on the Sanctions Guidance page.

Contact details for enquiries

If you require any further information or guidance, please contact the Sanctions Team on:

Telephone: +44 1624 648109

Email: sanctions@gov.im

Please note: We are unable to provide legal advice. You may need to seek independent legal advice.

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