Tracing SanctionS Evasion Through Dubai's Luxury Real Estate Market


While an estimated $2.1 trillion is generated in illicit capital per year, less than 1% is seized. Of this, 30% of all criminal proceeds seized have historically been real estate.

In this report, C4ADS identifies 44 properties worth approximately $28.2 million held directly by sanctioned individuals, and an additional 37 properties worth approximately $78.8 million within these individuals’ expanded networks.


Syrian Fuel 



Wael Abdulkarim and Ahmad Barqawi were sanctioned for smuggling fuel to Syria in support of the government's military operations. They have been associated with three properties in the UAE collectively worth $867,067. They have also continued smuggling fuel to Syria at a higher frequency than before sanctions and as recently as May 2018, using the same vessels as well as previously unidentified and unsanctioned vessels and companies.

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Mexican Narcotics Trafficking


Hassein Eduardo Figueroa Gomez was sanctioned for smuggling precursor chemicals to Mexican cartels for narcotics production, and was indicted for money laundering in the US. He has been connected to three properties in the UAE worth $4.3 million, and seven unsanctioned companies across the UAE and Cyprus owned and directed in conjunction with two unsanctioned associates.  


Iranian Nuclear Proliferation


Kambiz Mahmoud Rostamian was sanctioned for procuring controlled material for the Iranian government's ballistic missiles program. In addition to his two properties worth $971,900, he has owned and operated two unsanctioned companies in the UK and Poland with ties back to Iran as recently as May 2018.


Pakistani Money Laundering


The Altaf Khanani Money Laundering Organization was sanctioned for laundering $14 to $16 billion annually for terrorist organizations, narco-traffickers, and organized crime groups. 

The sanctioned members hold 27 properties in the UAE worth $15 million, with a further 32 properties worth $6.66 million in their expanded network. They also maintain direct ties to 12 unsanctioned companies, including active money exchanges in the US, the UK, and the UAE.


Iranian Nuclear Proliferation


Hossein Pournaghshband was sanctioned for procuring dual-use materials for the Iranian government's ballistic missiles program. He has been associated with five properties in the UAE worth $3.1 million, and corporate ties to unsanctioned individuals and companies in Iran, the UAE, and China.


Syrian Grand 



Rami and Ihab Makhlouf were sanctioned as key facilitators and enablers of the Syrian conflict and benefactors of war-fueled corruption. They have been associated with four properties in the UAE worth approximately $3.17 million. Additionally, they have been linked to seven unsanctioned companies in Lebanon and the UAE, with ties to expanded corporate networks in Romania and Austria.


Hezbollah Terror Financing


Kamel and Issam Amhaz were sanctioned for procuring electronics used in Hezbollah military operations. In addition to Issam's single property worth $815,102, the Amhaz brothers have served on six unsanctioned companies in Lebanon and Hong Kong.

Their key corporate associates, in addition to serving on sanctioned and unsanctioned companies with the brothers, separately hold $70 million worth of property in the UAE, 30 properties in the US, five electronics companies in the UAE, and an extensive network of Lebanese companies tied to corruption and illicit finance schemes in Liberia and arms and security companies in Lebanon and the Czech Republic.