On January 23, 2017, efforts were being mobilized during the Astana negotiations to reach a settlement among the parties to the Syrian conflict. At the same time, the official in charge of reporting on money laundering activities at the Alemán, Cordero, Galindo & Lee law firm
was in the process of submitting a report written earlier on January 11 to the British Virgin Islands Financial Investigation Agency: The subject was a suspicious financial activity regarding three companies registered in BVI.
The three companies included in the report are Libra Investments Trading, Samya Investment Limited and Sunset Real Estate Properties Limited. They are owned by Syrian businessman Samir Hassan whose name has been on the European sanctions list since 2011 for funding the Assad regime.
This investigation is based on leaked documents obtained by the International Consortium of investigative Journalists ( ) and shared with ARIJ and a large number of publishers around the world within a project labeled as the Pandora Papers. The leaks mark the biggest cross-border journalistic collaboration project in history and include millions of documents from law firms about tax havens. They also uncover assets, secret transactions and the hidden fortunes of the rich, including more than 130 billionaires, more than 30 world leaders, a number of fugitives or convicted people alongside sports stars, judges, tax officials and counterintelligence agencies.
The investigation reveals that Hassan’s companies in the British Virgin Islands continue their activities despite the sanctions that have been imposed/ continued their activities despite the sanctions that had been imposed on him since the beginning of the Syrian revolution. Moreover, Hassan established a new company in 2015. This company specializes in real estate, which is one of his areas of focus in Syria.
Although the financial authorities of the Virgin Islands knew the identity of the owner of the companies, these were dissolved in September 2017 in violation of European Sanctions Resolution No . (36) of 2012.
In the aftermath of the Syrian revolution, the European sanctions list included a number of businessmen who are close to the Syrian regime. The list included Samir Hassan “because of his close working relationship with Maher Al-Assad, and because he is known for funding the Syrian regime.”
European sanctions against Samir were renewed in September 2014. One of the newly added reasons for his inclusion on the list was the influence he has in the two Syrian companies, Emaar Group and Al-Sham Holding. Hassan also has business relations with the cousin of Syrian President Bashar Al-Assad, Rami Makhlouf.
Al-Sham Holding Company was launched in 2006 after Rami Makhlouf announced his plans to launch a company that would bring together 70 investors of the most prominent Syrian businessmen. Makhlouf served as the company’s vice president.
Emaar and Al-Sham Holding companies merged into one company called “Emaar Al-Sham” with the aim of developing a number of multi-purpose projects in the most significant Syrian regions.
The US Department of the Treasury singled out Al-Sham Holding and issued a list of companies that “support the corrupt efforts of reconstruction by the Assad regime.” In a statement issued in 2020, the Department added that the company is supervising the establishment of Marota City in the areas that were seized and against whose development Legislative Decree No. (19) of 2015 was issued.
In 2020, the Pro-Justice Foundation issued a report entitled “The Network of Businessmen to Fund the Syrian Regime and Circumvent International Sanctions.” The report stated that Samir Hassan manages the money of the Makhlouf family and of other people close to the Syrian regime in their food import business activities.
The Russian International Affairs Council research center issued another report which highlighted that Hassan’s investment in “the food industry is also vital during the reconstruction of Syria because Hassan will be able to provide materials and products needed to revive the agricultural sector, and this is one of the largest contributors to Syria’s GDP.”
Even though the food industries are not covered by international sanctions, the European sanctions resolution confirmed that Samir contributes to the war effort by making cash donations to the regime.
One of the reasons for the renewal of the sanctions against Samir Hassan was that he headed the Syrian-Russian Business Council.
The Pro-Justice Foundation report indicates that Samir Hassan “facilitates financial transfers to the regime through the Russian Cobit companies, which include 158 major companies and which opened a branch of the bank in Syria to solve this problem.”
About three months before the renewal of the European sanctions, Samir was desperate to lift the European sanctions through his lawyer while the European General Court rejected the case. In April 2015, this was followed by the approval of the British Virgin Islands Financial Services Commission of the economic sanctions imposed by the European Union on those connected to the Syrian regime.
The Pandora Papers leaks, however, reveal that the opposite happened; not only did Hassan’s companies continue their activities in the Virgin Islands, but they also expanded through the establishment of a new company.
A leaked document reveals that the Syrian businessman Samir Hassan set up the Sunset company in the British Virgin Islands in November 2015 to carry out real estate and property related business activities.
In the same month, Hassan was in the process of resigning as director of Libra Investments Trading Limited, which was located in the Virgin Islands while another leaked document reveals that in July 2016 he owned 10,000 shares in the same company.
The same leaked document lists Samir Hassan’s address in Damascus for those who hold most of the shares of Libra, which was established in 2002.
In both companies, the Lebanese lawyer Tariq Makkawi obtained a Power of Attorney to carry out banking transactions and to conclude deals on their behalf, and this adds more mystery to the business of the two companies.
The research on Makkawi showed that he is the founder of and a partner in seven companies in Lebanon. He is also a member of the board of directors of a company engaged in “negotiating and signing contracts and agreements on operations and transactions implemented outside Lebanon.”
The services provided by this company to the offshore companies include “negotiating, signing contracts, shipping goods, and reissuing invoices for operations outside Lebanon or for the customs free zones heading to the country. This includes using the facilities available in the customs free zone in Lebanon to store imported goods for re-exportation purposes.”
Larissa Normanton is the Head of the Middle East and North Africa Division at Aperio Intelligence, which specializes in assessing transparency in economic transactions, says: “As US and European sanctions on Syria have increased over the past ten years, Syrian businessmen have taken advantage of Lebanon’s financial secrecy laws and offshore structures that have provided the transparency needed to operate front companies.”
We contacted Tariq Makkawi to learn about his role in facilitating Hassan’s circumvention of European sanctions, but he did not respond to us.
Tariq Makkawi is the eldest son of the Lebanese politician
one of the founders of the Lebanese Najjadeh Party. Jamil Makkawi held the
of Minister of Public Works and Transport between 1955 and 1956 and Minister of Finance for a year from 1957 to 1958.
According to the registry of Lebanese companies, Tariq Mekkawi is a partner with a number of businessmen in companies operating in various activities in Lebanon.
The document leaked in April 2017 clearly indicates that the ultimate beneficiary of Sunset is Samir Hassan. The document included a declaration by the official in charge of reporting on money-laundering activities at the law firm: He explains that the person posing as the firm’s client, that is Hassan, is aboveboard and that neither his character nor integrity or reputation conflict with the firm’s standards. If such suspicion should arise, he would inform the management immediately.
The same official had previously submitted a report in January 2017 to the Virgin Islands Financial Investigation Agency about suspicious financial activities for three companies, including Sunset.
The report was filed because Samir Hassan was the ultimate beneficiary of the three listed companies of Libra Investments Trading, Samya Investment Limited and Sunset Real Estate Properties Limited. Hassan was on the European sanctions list that was extended till June 2017. Two months before this date, the law firm employee had pledged that he was not suspicious of the owner of Sunset.
In this way, the authorities came to know that Samir Hassan who is on the sanctions list owns companies in areas under their jurisdiction.
More than a year later, in March 2018, the Financial Investigation Agency informed the law firm that it had completed its investigation into the suspicious financial activity report previously filed by the law firm and that it had referred the firm’s report to the Virgin Islands Financial Services Commission.
However, a document issued by the Financial Services Commission in April 2018 reveals that Samir Hassan’s companies were dissolved in September 2017.
This violates Article (14) of European Union Resolution No. (36) of 2012 on restrictive measures on the Syrian regime stating that “All funds and economic resources belonging to, owned, held or controlled by the natural or legal persons, entities and bodies listed in Annex II and IIa shall be frozen.”
Paragraph (i) of Article (1) of the European Sanctions Decision explains that “'freezing of funds' means preventing any move, transfer, alteration, use of, access to, or dealing with funds in any way that would result in any change in their volume, amount, location, ownership, possession, character, destination or other change that would enable the funds to be used, including portfolio management”.
For more than six years, Samir Hassan’s companies have escaped the penalties of European and British sanctions and continued to operate in the British Virgin Islands in peace despite a suspicious financial activities report filed with the authorities by these companies’ registry agents. The response of the British authorities came too late after the companies “disappeared from the companies’ records.”