On April 24, 2017, the United States sanctioned 271 employees of Syria’s Scientific Studies and Research Center (SSRC) in response to the Assad government’s April 4 sarin gas attack in Khan Sheikhoun. These individuals were added to the Treasury Department’s Specially Designated Nationals (SDN) list under Executive Order 13582, which targets the Syrian government and its supporters. In addition to being expeditious – coming just weeks after the sarin attack – this action is noteworthy for the number of individuals designated at one time, and employed by a single entity. The designations aim to further punish SSRC itself, rather than the contribution of any single individual. As such, the action highlights SSRC’s central role in Syria’s non-conventional weapon programs.
SSRC is a Syrian government agency that oversees the development and production of chemical weapons.[1] It also is involved in the development of biological weapons, missiles, and reportedly was connected to Syria’s now-abandoned nuclear weapons program.[2] SSRC oversees the procurement of technology for these programs as well, operating a number of front companies for this purpose. In recent years, these front companies have imported or attempted to import a large number of weapons-related items, primarily from Iran and North Korea. Arms shipments have included graphite cylinders used in rocket nozzles and reentry vehicles,[3] propellant blocks used in Scud missiles,[4] and precursors for the nerve agent soman.[5] The SSRC continues to operate, despite the partial dismantlement of Syria’s chemical weapons program being overseen by the Organization for the Prohibition of Chemical Weapons. The Treasury Department continues to identify SSRC front companies and procurement agents.[6] Also, on April 26, 2017, France released a report confirming that SSRC’s sarin manufacturing process was used by the Syrian regime in the attack on Khan Sheikhoun.[7] The report also asserts that since 2014 Syria has attempted to acquire dozens of tons of isopropanol, a key component in the synthesization of sarin.[8]
SSRC’s role in Syria’s non-conventional weapon programs has made the organization and the individuals and companies associated with it the target of U.S. sanctions for some time. In fact, SSRC was one of eight entities originally designated in June 2005, when the George W. Bush administration issued E.O. 13382 as a means of targeting proliferators of weapons of mass destruction and their delivery systems.[9] Both E.O. 13382 and E.O. 13582, which was used to designate the 271 individuals this week,[10] impose the same restrictions: an asset freeze and a prohibition on transactions with U.S. parties.[11]
Earlier this year, pursuant to E.O. 13382, Treasury designated several SSRC officials for their specific actions related to the production and use of chemical weapons, including Brigadier General Ghassan Abbas who was involved in planning the August 2013 sarin gas attack in the Damascus suburb of Ghouta. And entities associated with SSRC have been regularly targeted by Treasury in previous years, notably in 2012, when five Damascus-based entities were designated for acting on behalf of SSRC by procuring chemical weapon material and missile technology. In addition, the United States has sanctioned a number of SSRC’s procurement agents in third countries, including Lebanon-based companies in 2015,[12] and several Dubai-based entities in 2016.[13]
SSRC is vulnerable to this net of ever-expanding sanctions. It continues to rely on overseas suppliers for weapons-related equipment and technology.[14] And the restrictive measures also aim to disrupt SSRC’s access to overseas bank accounts and its ability to transfer funds. The hundreds of individual SSRC employees sanctioned this week may have difficulty traveling overseas and conducting foreign transactions, now that they have been frozen out of a large portion of the world’s financial system.
Treasury Secretary Steven Mnuchin said that this week’s broad action is intended to “pursue and shut down the financial networks of all individuals involved with the production of chemical weapons.”[15] To achieve this end, the United States should encourage its partners to do the same. The European Union has already imposed restrictive measures on hundreds of entities supporting the Syrian regime’s violent repression of its civilian population, including SSRC and its associates.[16] And SSRC and a handful of its affiliates are on a Japanese government warning list.[17] Other countries should do the same, because no specific action against this organization is likely at the United Nations. A draft U.N. resolution introduced last February by 42 countries, including the United States, called for 20 Syrian entities to be blacklisted, including SSRC. The resolution was vetoed by Russia and China.[18]
Footnotes:
[1] “Treasury Targets Syrian Regime Financial and Weapons Networks,” Press Release, U.S. Department of the Treasury, March 31, 2015, available at http://www.treasury.gov/press-center/press-releases/Pages/JL10013.aspx, accessed on April 25, 2017; United Nations Security Council Draft Resolution, S/2017/172, February 28, 2017, pp. 9-10, available at http://www.securitycouncilreport.org/atf/cf/%7B65BFCF9B-6D27-4E9C-8CD3-CF6E4FF96FF9%7D/s_2017_172.pdf, accessed on April 6, 2017; “Fact Sheet: Increasing Sanctions Against Syria,” Office of Public Affairs, U.S. Department of the Treasury, July 18, 2012, available at http://www.treasury.gov/press-center/press-releases/Documents/Fact%20Sheet.pdf, accessed on April 25, 2017.
[2] “Fact Sheet: Increasing Sanctions Against Syria,” Office of Public Affairs, U.S. Department of the Treasury, July 18, 2012, available at http://www.treasury.gov/press-center/press-releases/Documents/Fact%20Sheet.pdf, accessed on April 25, 2017; Robin Hughes, “SSRC: Spectre at the Table,” Jane’s Defense Weekly, January 22, 2014, available via Jane’s Information Group (www.janes.com), accessed on April 25, 2017.
[3] “Report of the Panel of Experts established pursuant to resolution 1874 (2009),” United Nations, S/2013/337, June 11, 2013, pp. 23-24, available at http://www.un.org/en/ga/search/view_doc.asp?symbol=S/2013/337, accessed on April 25, 2017.
[4] “Report of the Panel of Experts established pursuant to resolution 1874 (2009),” United Nations, S/2012/422, June 14, 2012, p. 24, available at http://www.un.org/en/ga/search/view_doc.asp?symbol=S/2012/422, accessed on April 25, 2017.
[5] “Fact Sheet: Increasing Sanctions Against Syria,” Office of Public Affairs, U.S. Department of the Treasury, July 18, 2012, available at http://www.treasury.gov/press-center/press-releases/Documents/Fact%20Sheet.pdf, accessed on April 25, 2017.
[6] “Progress in the Elimination of the Syrian Chemical Weapons Program,” Organization for the Prohibition of Chemical Weapons, EC-85/DG.5, April 24, 2017, available at https://www.opcw.org/fileadmin/OPCW/EC/85/en/ec85dg05_e_.pdf, accessed on April 27, 2017; “Treasury Targets Syrian Regime Financial and Weapons Networks,” Press Release, U.S. Department of the Treasury, March 31, 2015, available at https://www.treasury.gov/press-center/press-releases/Pages/JL10013.aspx, accessed on April 25, 2017; “Treasury Sanctions Networks Providing Support to the Government of Syria,” Press Release, U.S. Department of the Treasury, July 21, 2016, available at https://www.treasury.gov/press-center/press-releases/Pages/jl0526.aspx, accessed on April 25, 2017.
[7] “National Evaluation – Chemical Attack of 4 April 2017,” French Ministry of Foreign Affairs and International Development, p. 4, available at http://www.diplomatie.gouv.fr/IMG/pdf/170425_-_evaluation_nationale_-_anglais_-_final_cle0dbf47-1.pdf, accessed on April 27, 2017.
[8] “National Evaluation – Chemical Attack of 4 April 2017,” French Ministry of Foreign Affairs and International Development, p. 5, available at http://www.diplomatie.gouv.fr/IMG/pdf/170425_-_evaluation_nationale_-_anglais_-_final_cle0dbf47-1.pdf, accessed on April 27, 2017.
[9] “Specially Designated Nationals and Blocked Persons List,” Office of Foreign Assets Control, U.S. Department of the Treasury, April 24, 2017, p. 257, available at https://www.treasury.gov/ofac/downloads/sdnlist.pdf, accessed on April 25, 2017; “Nonproliferation: What You Need to Know About Treasury Restrictions,” U.S. Department of the Treasury, Office of Foreign Assets Control, available at http://www.treasury.gov/resource-center/sanctions/Programs/Documents/wmd.pdf, accessed on April 25, 2017; “Fact Sheet: Increasing Sanctions Against Syria,” Office of Public Affairs, U.S. Department of the Treasury, July 18, 2012, available at http://www.treasury.gov/press-center/press-releases/Documents/Fact%20Sheet.pdf, accessed on April 25, 2017; “Syria Designations; Non-proliferation Designations,” U.S. Department of the Treasury, Office of Foreign Assets Control, July 18, 2012, available at https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pages/20120718.aspx, accessed on April 25, 2017; “Treasury Sanctions Companies for Aiding the Syrian Regime,” Press Release, U.S. Department of the Treasury, July 9, 2014, available at https://www.treasury.gov/press-center/press-releases/Pages/jl2558.aspx, accessed on April 25, 2017; “Syria Designations; Non-proliferation Designations,” U.S. Department of the Treasury, Office of Foreign Assets Control, July 9, 2014, available at https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pages/20140709.aspx, accessed on April 25, 2017.
[10] “Syria Designations,” U.S. Department of the Treasury, Office of Foreign Assets Control, April 24, 2017, available at https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pages/20170424.aspx, accessed on April 25, 2017; “Executive Order 13582-Blocking Property of the Government of Syria and Prohibiting Certain Transactions With Respect to Syria, the White House, Federal Register, Volume 76, Number 162, August 17, 2011, pp. 52209-52211, available at https://www.treasury.gov/resource-center/sanctions/Programs/Documents/syria_eo_08182011.pdf, accessed on April 25, 2017; “Specially Designated Nationals and Blocked Persons List,” Office of Foreign Assets Control, U.S. Department of the Treasury, April 24, 2017, p. 1036, available at https://www.treasury.gov/ofac/downloads/sdnlist.pdf, accessed on April 25, 2017.
[11] “Nonproliferation: What You Need to Know About Treasury Restrictions,” U.S. Department of the Treasury, Office of Foreign Assets Control, available at http://www.treasury.gov/resource-center/sanctions/Programs/Documents/wmd.pdf, accessed on April 25, 2017; “Executive Order 13582-Blocking Property of the Government of Syria and Prohibiting Certain Transactions With Respect to Syria, the White House, Federal Register, Volume 76, Number 162, August 17, 2011, pp. 52209-52211, available at https://www.treasury.gov/resource-center/sanctions/Programs/Documents/syria_eo_08182011.pdf, accessed on April 25, 2017.
[12] “Treasury Targets Syrian Regime Financial and Weapons Networks,” Press Release, U.S. Department of the Treasury, March 31, 2015, available at https://www.treasury.gov/press-center/press-releases/Pages/JL10013.aspx, accessed on April 25, 2017.
[13] “Treasury Sanctions Networks Providing Support to the Government of Syria,” Press Release, U.S. Department of the Treasury, July 21, 2016, available at https://www.treasury.gov/press-center/press-releases/Pages/jl0526.aspx, accessed on April 25, 2017.
[14] “Report of the Panel of Experts established pursuant to resolution 1874 (2009),” United Nations, S/2016/157, February 26, 2016, pp. 29-30, available at http://www.securitycouncilreport.org/atf/cf/%7B65BFCF9B-6D27-4E9C-8CD3-CF6E4FF96FF9%7D/s_2016_157.pdf, accessed on April 25, 2017; “Treasury Sanctions Networks Providing Support to the Government of Syria,” Press Release, U.S. Department of the Treasury, July 21, 2016, available at https://www.treasury.gov/press-center/press-releases/Pages/jl0526.aspx, accessed on April 25, 2017; “Treasury Targets Syrian Regime Financial and Weapons Networks,” Press Release, U.S. Department of the Treasury, March 31, 2015, available at https://www.treasury.gov/press-center/press-releases/Pages/JL10013.aspx, accessed on April 25, 2017.
[15] “Treasury Sanctions 271 Syrian Scientific and Research Center Staff in Response to Sarin Attack on Khan Sheikhoun,” Press Release, U.S. Department of the Treasury, April 24, 2017, available at https://www.treasury.gov/press-center/press-releases/Pages/sm0056.aspx, accessed on April 25, 2017.
[16] Council Regulation (EU) No 36/2012 of 18 January 2012 concerning restrictive measures in view of the situation in Syria and repealing Regulation (EU) No 442/2011 (Consolidated Version March 21, 2017), available at http://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:02012R0036-20170321&rid=3, accessed on April 27, 2017.
[17] “End User List,” Japan’s Ministry of Economy, Trade and Industry (METI), March 29, 2016, pp. 24-25, available at http://www.meti.go.jp/policy/anpo/law_document/tutatu/kaisei/150415_user-list-tokekomashi.pdf, accessed on April 27, 2017.
[18] United Nations Security Council Draft Resolution, S/2017/172, February 28, 2017, available at http://www.securitycouncilreport.org/atf/cf/%7B65BFCF9B-6D27-4E9C-8CD3-CF6E4FF96FF9%7D/s_2017_172.pdf, accessed on April 27, 2017; Journal of the United Nations, No. 217/41, March 1, 2017, available at http://www.un.org/Docs/journal/En/20170301e.pdf, accessed on April 27, 2017.