Case No. SOM-2017-339163-1

Date issued: Jan. 01 1970

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TURBOFAC Commentary (632 words)

Notes:

1) BACKGROUND

On April 12, 2010, the president issued EO 13536, designating the entity Al-Shabaab (also an FTO/SDGT) and 11 individuals, two of whom were described as being central to Somali piracy activities. See https://ofac.treasury.gov/media/8531/download?inline (“Information on Persons Listed in the Annex to E.O. 13536 of April 12, 2010”). One individual was described as “a key organizer, recruiter, financier and commander of a maritime militia consisting of approximately 500 operating pirates, with responsibility for hijacking between 25 and 60 shipping vessels since the mid-1990s.” The other was “a principal organizer and financier of pirate activities”.

As evident from the guidance letter, on April 4, 2010 (just one week prior to the issuance of EO 13536), the M/T SAMHO DREAM was hijacked by Somali pirates. According to court filings (see PDF), the...