IRAQI Militia Exploiting ResourcES
Mustafa Hashim Lazim Al-Behadili (Al-Behadili), also known as Sayyid Awn, is a leader and economic official for AAH. Following the U.S. withdrawal from Iraq in 2011, Al-Behadili played an important role in developing an oil trucking and security unit, allowing AAH to become a dominant actor in the Iraqi metals industry, as well as enabling AAH’s entrance into fuel oil theft, which focused on stolen or subsidized oil.
Working directly with U.S.-designated AAH senior leader Laith Al-Khazali, Al-Behadili controlled oil smuggling financing and oversaw mineral industry activities for AAH. In southern Iraq, Al-Behadili managed oil smuggling operations and AAH projects, using businesses, projects, and government contracts as a front for AAH financial activity.
As part of his activities on behalf of AAH, Al-Behadili was also complicit in dealing directly with Iran and the Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF), a U.S.-designated terrorist organization. In his capacity as AAH Economic Committee member, Al-Behadili was involved in negotiating contracts to ship oil from Iran and coordinating with the IRGC-QF on shipping AAH’s oil.
Mustafa Hashim Lazim Al-Behadili 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, Asa’ib Ahl Al-Haq.
Al-Behadili owns or controls four Iraqi companies that operate in the oil sector—Gulf Energy Oil Services Limited, Gulf General Contracting Limited, Iraq International Energy for the Import and Sale for Petroleum Products Limited, and Gulf Energy for General Transport and Marine Services and Real Estate Consultancy LLC—all of which are being designated pursuant to E.O. 13224, as amended, for being owned, controlled, or directed by, or having acted or purported to act for or on behalf of, directly or indirectly, Mustafa Hashim Lazim Al-Behadili.
Iran-BACKED TERRORIST MILITIA OFFICIALS
Kata’ib Sayyid al-Shuhada (KSS) is an Iran-aligned terrorist militia that has planned and executed numerous attacks against U.S. personnel in Iraq and Syria. Ahmed Khudair Maksus Maksus is the former KSS Deputy Secretary General under U.S.-designated Secretary General Hashim Finyan Rahim al-Saraji.
Mohammed Issa Kadhim al-Shuwaili (Al-Shuwaili), operating under the alias Abu Maryam, is a senior KSS official. Since at least 2025, Al-Shuwaili has collaborated directly with Hizballah illicit finance team members, including Ali Qasir, on the purchase and delivery of weapons into Iraq. Al-Shuwaili also arranged the payment of millions of dollars to Hizballah to facilitate the purchase of weapons, and coordinated logistics related to the transfer and delivery of the weapons with Hizballah associates.
Ahmed Khudair Maksus Maksus is being designated pursuant to E.O. 13224, as amended, for being owned, controlled, or directed by, or having acted or purported to act for or on behalf of, directly or indirectly, Kata’ib Sayyid al-Shuhada. Mohammed Issa Kadhim al-Shuwaili 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, Ali Qasir, a person whose property and interests in property are blocked pursuant to E.O. 13224, as amended.
SANCTIONS IMPLICATIONS
As a result of today’s action, all property and interests in property of the designated or blocked persons described above that are in the United States or in the possession or control of U.S. persons are blocked and must be reported to OFAC. In addition, any entities that are owned, directly or indirectly, individually or in the aggregate, 50 percent or more by one or more blocked persons are also blocked. Unless authorized by OFAC, or exempt, OFAC’s regulations generally prohibit all transactions by U.S. persons or within (or transiting) the United States that involve any property or interests in property of blocked persons.
Violations of U.S. sanctions may result in the imposition of civil or criminal penalties on U.S. and foreign persons. OFAC may impose civil penalties for sanctions violations on a strict liability basis. OFAC’s Economic Sanctions Enforcement Guidelines provide more information regarding OFAC’s enforcement of U.S. economic sanctions.
In addition, financial institutions and other persons may risk exposure to sanctions for engaging in certain transactions or activities involving designated or otherwise blocked persons.
The prohibitions include the making of any contribution or provision of funds, goods, or services by, to, or for the benefit of any designated or blocked person, or the receipt of any contribution or provision of funds, goods, or services from any such person.
Non-U.S. persons are also prohibited from causing or conspiring to cause U.S. persons to wittingly or unwittingly violate U.S. sanctions, as well as engaging in conduct that evades U.S. sanctions. Individuals located in the U.S. or abroad who provide information about sanctions violations to Treasury’s Financial Crimes Enforcement Network (FinCEN) whistleblower incentive program may be eligible for awards if the information they provide leads to a successful enforcement action that results in monetary penalties exceeding $1,000,000. FinCEN is currently accepting whistleblower tips.
Furthermore, engaging in certain transactions involving the persons designated today may risk the imposition of secondary sanctions on participating foreign financial institutions. OFAC can prohibit or impose strict conditions on opening or maintaining, in the United States, a correspondent account or a payable-through account of a foreign financial institution that knowingly conducts or facilitates any significant transaction on behalf of a person who is designated pursuant to the relevant authority.
The power and integrity of OFAC sanctions derive not only from OFAC’s ability to designate and add persons to the 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.
https://home.treasury.gov/news/press-releases/sb0492
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