As the conflicts there endure, networks of public and private sector actors in Syria, Libya, and Yemen have been the target of sanctions by the international community. The confluence of sanctioned actors, political interests, and proxies creates exceptionally complicated environments in which to do business. These risks have also spilled over into other regions as the facilitation and support networks of these targeted groups traverse the world.

In this briefing, Kharon experts will provide an overview of the relevant guidance and international best practices, recent developments and enforcement actions, and real-life case studies that demonstrate the most up-to-date risk typologies relevant to identifying and managing risk in connection with these three states.

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About Kharon: Founded and led by former senior officials from the U.S. Department of the Treasury, Kharon’s mission is to provide the most comprehensive and reliable way to identify, understand, and mitigate exposure to sanctioned networks and jurisdictions for financial institutions and corporates. Kharon goes far beyond the government sanctions lists to identify the networks of supporters and facilitators surrounding sanctioned actors that may also pose threats to global security, financial crime compliance and trade control frameworks, and reputations. Kharon enables firms to proactively identify and manage this otherwise hidden risk.


Bryan Stirewalt was appointed Chief Executive of the DFSA on 1 October, 2018, after nearly 8 years as the DFSA’s Managing Director of the Supervision Division. In his role as Chief Executive, Bryan will take the lead in steering the work of the DFSA and further developing its capability as a robust regulator delivering world-class financial regulation in the DIFC. Over his time with the DFSA, Bryan has played a vital part in executing the DFSA’s regulatory mandate and developing its risk-based supervision framework. Prior to joining the DFSA, Bryan developed his skills over a career that spans more than 30 years. He has held a number of senior positions in financial regulation, both in the public and in private sectors. From 1985 to 1996, he worked for the US Treasury’s Office of the Comptroller of the Currency as a National Bank Examiner, specialising in policy development and implementation, problem bank rehabilitation and banking fraud initiatives. From 1996 until joining the DFSA in 2008, he worked for an international consulting and advisory firm, focusing on emerging markets development programmes in Poland, Ukraine, Cyprus and Kazakhstan.

Mark Nakhla served twice as a sanctions officer at the Office of Foreign Assets Control (OFAC) at the U.S. Treasury Department. Currently, he is Executive Vice President of Kharon, where he is responsible for the integrity and strategic direction of all Kharon research for terrorism and Middle East-related sanctions programs. Mark has deep domain expertise on the activities of terrorist support networks and other groups targeted by international sanctions. At OFAC, Mark served as a sanctions officer investigating terrorist groups and their networks of financiers and facilitators in the Middle East, Asia and beyond. Mark previously served at the US Department of Defense as a Middle East policy adviser, and at Booz Allen Hamilton, where he focused on strategic research and policy planning. In 2020, Mark was named a Shawn Brimley Next Generation National Security Leader by the Center for a New American Security (CNAS).

William G. Rich is the former U.S. Treasury Attache in UAE and former Senior Policy Advisor for the Middle East and North Africa in the Office of Terrorist Financing and Financial Crimes at Treasury. He is currently Managing Director of Kharon MEA and Senior Vice President for Public and Emerging Markets at Kharon. He manages Kharon’s UAE office and leads efforts to expand into new markets and advise government and regulatory clients. From 2015 to 2018, Will served as the U.S. Treasury’s senior-most representative to the largest financial center in the greater Middle East, South Asia, and Africa. He previously served in national security policy, counterterrorism, and intelligence positions both domestically and overseas. Immediately prior to joining Kharon, Will was a visiting fellow at the Council on Foreign Relations (CFR) where his work was featured by The Wall Street Journal, Bloomberg, and WIRED. He was also an adjunct faculty member at Columbia University in New York and Visiting Scholar at New York University.