The resolution was adopted by a majority of 85 countries during the third committee meeting. The resolution condemns ongoing human rights violations in Syria, including attacks on civilians, the use of chemical weapons, arbitrary arrests, torture, and enforced disappearances. The resolution also emphasizes the need to protect civilians and hold those responsible for crimes against humanity accountable under international law.

This achievement reflects the Syrian Forum’s efforts, which included organizing side events, engaging with international experts and diplomats, and preparing a specialized legal study on advancing justice. The Forum also conducted intensive advocacy tours in key cities like The Hague, New York, and Geneva, presenting reports and testimonies highlighting the suffering of the Syrian people.

The resolution also calls for ensuring unhindered humanitarian aid access to all affected areas in Syria, with a focus on protecting the most vulnerable groups. It underscores the importance of completing the political process in accordance with UN Security Council Resolution 2254.

The Syrian Forum emphasizes that this resolution is a significant milestone in the pursuit of justice for the Syrian people. It calls on the international community to translate these commitments into tangible actions to end the suffering of Syrians. The Forum reaffirms its commitment to continuing its efforts on the international stage to achieve justice, accountability, and a future that guarantees dignity and rights for all Syrians.

Syrian Forum

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During this participation, they attended high-level ministerial meetings with international leaders and diplomats, where the suffering of the Syrian people was highlighted, and the Syrian cause was firmly established as a key issue on the global agenda. These efforts reflect the Syrian Forum’s ongoing commitment to keeping the Syrian issue at the forefront of international discussions and advocating for the rights of the Syrian people in all forums.

In addition to these meetings, Sally Shobut participated in closed high-level sessions with prominent international and diplomatic delegations, where she provided a detailed overview of the programs and initiatives led by the Syrian Forum to support Syrians inside Syria and in refugee areas. These meetings addressed the efforts to enhance humanitarian support in Syria, and the development of civil society infrastructure, contributing to the empowerment of the Syrian communities most affected by the crisis.

Shobut also joined a high-level session attended by Queen Maxima of the Netherlands and a number of senior global executives and prominent international figures from the Netherlands, Peru, and Indonesia during the launch of a comprehensive report covering 15 years of global achievements in sustainable development financing. The report highlighted the positive impact of these efforts in boosting economic opportunities and reducing poverty worldwide, which aligns with the Syrian Forum’s vision of achieving sustainable development in conflict-affected areas in Syria.

The events held this week in New York led to profound discussions that reinforced the importance of international cooperation to achieve sustainable change and push for the development of comprehensive solutions to support vulnerable communities, especially in Syria, as well as in various affected areas around the world.

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The event focused on the legal aspects through which the Syrian file could be referred to the ICC, based on a preliminary study prepared by LAW and an in-depth study conducted by the Syrian Forum. During the session, the legal foundations for such a referral were discussed, relying on the legal precedent set by the case of forced displacement in Myanmar and Bangladesh, which was referred to the ICC for investigation at the court’s request.

Participants emphasized that this step comes at a time when the role of the ICC is becoming more significant, particularly after it issued arrest warrants for political leaders from both Israel and Hamas amid the ongoing Gaza conflict. They highlighted that this reinforces the importance of international law as a tool for achieving justice, especially in light of the UN Security Council’s failure to maintain international peace and security in Ukraine and the Middle East.

In a statement during the session, Yaser Tabbara, lawyer and Chief Strategist at the Syrian Forum, said:

“The veto that blocked the referral of the Syrian file to the ICC does not signify the end of the road to justice. Relying on the precedent of forced displacement in Myanmar and Bangladesh could provide a legal pathway to investigate crimes committed in Syria without needing a Security Council resolution.”

Tabbara also stressed that countries that believe in the importance of international justice should take an active stance in supporting the referral of the Syrian file to the ICC, stating:

“Support from nations for these efforts is crucial because the continuation of impunity in Syria exacerbates the situation and poses a threat to regional and international security.”

He added: “Countries that believe in international justice have a pivotal role in supporting these efforts. Members of the Human Rights Council and the United Nations must act more seriously because achieving justice in Syria is not only a human rights demand but a necessity for regional stability. Allowing perpetrators to go unpunished will keep the door open for further violations.”

The speakers, including Antonia Mulvey, Executive Director of LAW, and Mazen Darwish, Director of the Syrian Center for Media and Freedom of Expression, discussed previous attempts to refer the Syrian file to the ICC, emphasizing the need to end the policy of impunity.

The participants explained that there are new legal developments that could allow for the referral of the Syrian file to the ICC without needing to go through the UN Security Council, making these efforts more feasible given the current political challenges.

The event concluded with a call for intensified international efforts to support these legal initiatives, emphasizing the importance of strengthening the role of the ICC as a tool to achieve justice and hold those responsible for crimes against humanity in Syria accountable.

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The popular uprising was only the beginning of a difficult journey, one that Syrians hoped would lead to the establishment of a democratic system that guarantees rights and respects freedoms. But the response to these demands was harsh and violent. Instead of dialogue and listening, the ruling regime chose repression and torture, turning prisons into places crowded with thousands of detainees and forcibly disappeared individuals. These detainees are not just numbers or isolated cases; they are human stories filled with unfulfilled hopes and dreams, with souls yearning for the day they will regain their freedom. Each detainee languishing in the darkness is a living reminder of the price paid in the struggle for democracy.

Democracy is not merely a political mechanism for organizing elections; it is a value system based on respect for humanity, representing all segments of the people in governance and law, while also promoting justice and equality. In Syria, the absence of justice remains one of the biggest obstacles to achieving a genuine democratic transition. How can we talk about democracy in the face of ongoing arbitrary arrests and torture? How can the Syrian people trust in a better future without holding the perpetrators of crimes accountable and without justice being served to the victims? The absence of justice renders any conversation about democracy incomplete, failing to address the root causes of the problem.

To set Syria on the path toward democracy, we must first achieve justice. Transitional justice is one of the key tools for addressing past violations and ensuring they are not repeated. The files of detainees and the disappeared must be opened, and there must be transparent and independent investigations to hold those responsible for crimes against humanity accountable. This process not only restores the rights of victims but also strengthens trust between the state and society, laying the foundations for lasting peace. Justice is not only a legal requirement; it is a humanitarian necessity that heals the wounds of families who have lost loved ones and restores the cohesion and strength of society.

In this context, the importance of the International Day of Democracy is highlighted, reminding the world of the need for countries to ensure the rights of their people and involve them in the political process. This year, the focus is renewed on “Empowering the Next Generation,” which aligns with what Syria needs today. Syrian youth, who have lived through war and destruction, and who have faced repression and marginalization, are the hope for rebuilding their homeland. Empowering them to participate politically and providing them with opportunities to express their opinions is the cornerstone of any future democratic transition. These young people are not just victims; they are also the leaders of the future, and their active participation is the guarantee for building a society based on justice and equality.

Therefore, the efforts of the international community and the United Nations must focus on supporting Syrian youth and providing the necessary education and training to enhance their awareness of their rights and responsibilities. Local initiatives that aim to document violations and provide legal and psychological support to victims should also be supported. Promoting legal awareness and spreading knowledge of human rights are two essential steps in shaping a generation capable of leading the democratic transition and participating in building a new future.

Today, more than ever, the international community is called upon to take responsibility for the Syrian people. There must be continuous international pressure on the regime to release political prisoners and reveal the fate of the forcibly disappeared. Initiatives for transitional justice must be supported, and the necessary resources must be provided to ensure justice is achieved. The path to democracy is not easy, but it is the only path to achieving lasting peace and real stability in Syria.

The dream of democracy remains alive in the hearts of Syrians, despite all the pain and suffering. It is the dream of mothers waiting for the return of their children, and the dream of young people who see in the future a hope for a dignified life. Achieving this dream requires a collective commitment to justice and freedom and a shared vision to build a homeland that accommodates everyone and respects the rights of every individual. Democracy is not an unattainable goal; it is a continuous process that begins with achieving justice and continues with involving everyone in building a future worthy of the sacrifices and aspirations of the Syrian people.

Sally Shobat

Advocacy Officer at the Syrian Forum

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SUMMARY

• In 2020, the EU sanctioned Maher (Mahir) Burhan Eddine al-Imam for benefiting from and financing the Syrian regime. The Court of Justice of the European Union (CURIA) dismissed his appeal on 22 September 2021 and ordered him to pay the court cost. However, the EU decided to delist him last month without public justification.
• Although Maher has toned down his public support for the regime and pulled out of some formal business dealings, he continues to control key companies with links to the regime through his business affiliate and friend, Muhammad Ammar Dalloul. On 20 April 2022, Maher transferred his shares from Waves Internet Service in what appeared on paper to be the severing of his last connection to the regime-backed Telsa Group. However, he merely transferred the shares to Dalloul, with whom he remains in close contact. Maher’s public engagements continue to suggest that he is in charge of Waves Internet.
• The EU should not have delisted Maher al-Imam. Instead, Muhammad Dalloul should have been sanctioned due to ample evidence of his business connections to both Maher and Maher’s wife, Khadija Bekdash, and of his support to and benefit from the Assad regime. The delisting of Maher al-Imam is another failure of Western governments to adequately understand the intricate web of business-regime networks in Syria.
• Western governments, and the EU, should overhaul the way they arrive at their listing and delisting decisions to improve the efficacy of their unilateral sanctions, especially in light of their negative unintended impacts on innocent civilians.^[1]

^[1] This report is produced by the Syria Sanctions Policy Program (SSPP). The SSPP is a joint initiative of the Syrian Forum and the Observatory of Political and Economic Networks that works toward reforming Western sanctions on the Assad regime.

WHO IS MAHER AL-IMAM?

Maher Burhan Eddine al-Imam is a leading businessman with interests in Syria’s tourism, telecommunications, and real estate sectors. The EU sanctioned Maher on 17 February 2020 because “As General Manager of the regime‐backed Telsa Communication Group as well as of Castro LLC, and through his other business interests, Maher Burhan Eddin al‐Imam benefits from the Syrian regime and supports its financing and lobbying policy as well as its construction policy.”

Telsa Group is a conglomerate of businesses working in Syria’s telecommunications and reconstruction sectors. Four major companies form Telsa Group, and Maher had partial ownership in all four.^[1] However, on Maher’s Facebook profile, a chart of entities comprising Telsa Group includes more companies—such as Telsa Telecom and Telsa Rebuild—which are not found in the Syrian Gazette, suggesting they are direct subsidiaries of Telsa Group.

The EU’s official sanctions website listed Maher as a Syrian national born on 22 August 1978, without stating his place of birth. However, while he is a Syrian national, he was born in Kuwait on 05 October 1976, according to the publicly available Syrian Gazette, when he registered one of his companies (Concurrence for Pledges and Contractors LLC) and his Facebook profile. This further highlights the EU’s inability to acquire accurately even the basic information about sanctions targets, such as the date and place of birth.

Maher’s family is originally from Damascus. They still have a residence there, although they have long been expatriates in Kuwait, according to sources interviewed for this report.

Our research in local and global business registers shows that between 2012 and April 2024^[2] Maher was a partial or full owner of fourteen companies in Syria.^[3] He also co-established two companies in Lebanon.^[4]

^[1] The four companies are: Concurrence Telecom LLC (Tazamun LLC), Concurrence for Pledges and Contractors LLC, Waves Internet Service LLC, and Concurrence for Trading and Building Materials.

^[2] Maher al-Imam’s first economic activity in Syria can be traced back to November 2011, when he registered his company Masar LLC.

^[3] Maher has been a partial or full owner of fourteen companies: Masar LLC, Waves Internet Service LLC, Concurrence (Tazamun) Telecom LLC, Concurrence for Pledges and Contractors LLC, Strategy LLC, Energy lines LLC, Like Syria LLC, On Line LLC, Castro LLC, Relife LLC, Ovaleo LLC, Telsa Group LLC, Telsa Mat LLC, and Concurrence for Trading and Building Materials.

^[4] In Lebanon, the first company was registered in 2013 under the name SAIS SARL, and the second in 2015 under the name Top Projects Company SARL.

WHY WAS HE SANCTIONED?

Before sanctions, Maher was openly loyal to the Assad regime. He used his Facebook page and television interviews to express his staunch loyalty.

In addition to interviews on Syrian TV, there were photos of Maher with sanctioned Syrian state figures like Presidential Advisor Buthaina Shaaban, the Minister of Communications, the Minister of the Interior, and the Minister of Information.

In his statements, Maher quoted President Bashar al-Assad and offered him blessings and greetings on multiple occasions.

Maher’s Telsa Group worked closely with government institutions and exhibited sanctionable behaviors:

• Telsa Rebuild implemented^[1] several projects and studies related to Marota City. Marota, a high-end real estate project in Damascus associated with the Syrian regime, and accused of forced displacement and property confiscation. The EU has sanctioned multiple institutions and individuals for their connections to the Marota City project.^[2]
• Telsa Group worked on improving satellite, wired, and wireless communication services for areas “regained by the Syrian Army.” It also provided network coverage to the areas and communication services for Syrian army personnel.
• Telsa Group also provided studies for the e-government project in coordination with Syria’s Ministry of Communications. Four Telsa Group entities participated in the Syrian Exhibition for Information Technology (SyriaTech 2016) in Damascus, which was held under the patronage of the Minister of Communications and Technology.^[3]

^[1] Maher mentioned in his Facebook post that the implementation covered Regulatory Zone Number 101, one of three zones included in the Marota City project according to this official source.

^[2] Sanctioned institutions due to their involvement in the Marota City project include Damascus Cham Holding Company, Muhammed Nazeer Jamal Eddin, and Mazin al-Tarazi.

^[3] Four Telsa Group entities participated in the Syrian Exhibition for Information Technology (“SyriaTech 2016”) in Damascus: Concurrence Telecom LLC, Telsa Telecom LLC, Concurrence for Pledges and Contractors LLC, and Waves Internet Service LLC.

HAS MAHER AL-IMAM CHANGED HIS BEHAVIOR?

After 2017, in what seemed like an attempt to avoid being sanctioned, Maher did not personally participate in television interviews or show public support for the regime on his social media. This behavior continued after his sanctioning in 2020, which probably helped him make a case for being delisted. In fact, after exactly two months of being sanctioned, Maher appealed to The Court of Justice of the European Union (CURIA) on 18 April 2020, seeking an annulment of the decision. Along with his request for priority treatment and for his identification details to be anonymized, Maher demanded compensation from the Council of the European Union in three parts:

1. EUR 10,000 for the material loss suffered.
2. EUR 15,000 per week from 18 February 2020 (the date sanctions went into effect) for the non-material loss suffered due to the restrictive measures.
3. An order for CURIA to compensate him for any future loss that he suffers as a result of the adoption of the restrictive measures taken against him.

On 22 September 2021, the case was dismissed, and Maher was ordered to pay the court cost.

Unfortunately, the public case report published by the court states that “only the paragraphs of the present judgment which the Court considers it appropriate to publish are reproduced here.” The report lacks any argument or discussion related to the role Maher plays in the political economy of Syria. The published arguments covered only Maher’s appeal that “the time limit for the submission of an application for review and for observations was too short, and thus did not allow him to be heard in a meaningful and effective way.” Even if he submitted evidence exonerating him, CURIA’s reviews are conducted annually “rather than being analysed immediately.”

His Facebook posts since then focus on social events like birthday parties and weddings, as well as important moments in his life like traveling for Umrah, undergoing surgery, and his father’s death.

However, his companies have continued to promote the regime, even as recently as 2021.

A post on the Facebook page of Telsa Rebuild—a subsidiary of Telsa Group—on 26 May 2021, expressing support for Syrian President Bashar al-Assad.

HOW TO DODGE SANCTIONS

To make his case for being delisted, Maher withdrew formally from multiple prominent companies in Syria, including those involved in government-related projects. He dissolved four of his fourteen Syria-based companies and relinquished his shares in four others, according to our review of official documents.^[1]

Maher’s shares in Concurrence Telecom (Telsa Telecom) and Concurrence for Pledges and Contractors went to a little-known businessperson known as “Rawan Abdel Rahman Al-Asbahi,” who might be acting as an informal nominee shareholder to conceal Maher’s ownership. The third company forming Telsa Group, Concurrence for Trading and Building Materials, was dissolved.

However, in spite of having no formal relationship with Telsa Telecom since 2020, Maher’s public engagements suggest he continues to play a prominent role in it as of 27 April 2023 and  20 September 2023.

^[1] Maher dissolved Castro LLC, Concurrence for Trading and Building Materials, Energy Lines LLC, and Masar LLC. By dissolving Energy Lines, Maher effectively severed his only formal connection to Mudar Tawfiq Younis. Younis is known for introducing what he called the “Syrian Financial Army,” which aimed to save the Syrian lira (pound) from depreciation in 2019. The “army” included numerous regime cronies, and Maher participated in several Facebook post discussions as part of the campaign “Let’s support our Lira.” Younis has also been accused of involvement in the narcotics trade in Syria. A huge stash of captagon was reportedly found in his car in 2018, although he managed to avoid conviction through his father’s (Major General Tawfiq Younis) connections. Maher relinquished his shares in Syria LLC, Concurrence Telecom LLC, Concurrence for Pledges and Contractors LLC, and Waves Internet Service, LLC. The lack of evidence of his exit from Strategy LLC, Ovaleo LLC, and Relife LLC are not of particular concern. These companies are not owned by regime affiliates or by any currently-sanctioned individuals or entities.

Maher al-Imam (far left) and Muhammad Ammar Dalloul (far right) pose for a photo at a Telsa Telecom event. Dalloul, discussed below, posted the image on his Facebook page on 27 April 2023.

In April 2022, Maher transferred his shares from Waves Internet Service, severing his last connection to the regime-backed Telsa Group—or at least it appeared so on paper. However, the shares went to his business partner and close friend Muhammad Ammar Dalloul, who has extensive connections to the Assad regime.

A document from the Syrian Ministry of Finance documenting Maher al-Imam’s transfer of 500 shares from Waves Internet Service to Muhammad Dalloul, dated 20 April 2022.

In spite of Maher having no formal connection to Telsa on paper, on 10 August 2023 Dalloul referred to Maher al-Imam and others in a Facebook post marking the seventh anniversary of the company.

On 8 March 2022 Dalloul also shared photos of the Telsa Group office, which has a special corner for images of Dalloul and Maher al-Imam together.

Muhammad Dalloul also shared a photo of himself and Maher at a cafe on 02 April 2024. Dalloul used the photo as his Facebook cover image, suggesting their close relationship.

A photo of Muhammad Ammar Dalloul (left) and Maher al-Imam (right), which Dalloul posted on Facebook on 02 April 2024 and uses as his Facebook cover image.

Dalloul still co-owns Mercato for Electronic Marketing LLC with Maher’s wife, Khadija Bekdash. The company was registered in Syria in 2022.

THE CASE FOR SANCTIONING MUHAMMAD DALLOUL

Muhammad Ammar Muhammad Mu’taz Dalloul is Vice Chairman of the Board and a founding partner and treasurer of the Syrian–Iranian Joint Chamber of Commerce, which is intimately connected to the Iranian and Syrian governments. The Iranian President attended one of its meetings, during which Dalloul briefed the media on its activities.

Dalloul is known for his staunch loyalty to President Bashar al-Assad. He has posted photos on his Facebook account showing him casting a ballot for Assad with the caption “You’re the hope, Bashar Hafez al-Assad.” Dalloul has also posted many photos with members of the Syrian Army and frequently congratulates ministers and public officials on their new governmental roles.

In a photo posted to Dalloul’s Facebook page on 07 February 2023 he (right) poses with a member of the Syrian army.

CONCLUSION

Maher al-Imam should not have been delisted from sanctions because of his strong connections to Dalloul, who seems to be serving as a front for him.

Although Maher has toned down his public displays of support for the regime, he is still embedded in the web of regime-backed-and-benefiting individuals and organizations.

It is critical to understand the intricate web the Assad regime has created to evade sanctions and benefit the ruling elite. A mere declaration on paper is far from substantial evidence to prove one’s severance of ties with regime-backed institutions in Syria—as Maher al-Imam’s case shows.

On paper, official ownership or shares can be transferred from one regime backer to another, allowing both to benefit and remain active while hiding behind the extensive interlinkages of regime cronies.

A better step toward accountability in Syria would have been to not only keep al-Imam on the sanctions list but to add his friend and business partner, Muhammad Dalloul, as well.

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A cornerstone of this nationwide journey was the organization’s engagement in numerous strategic meetings and profound discussions, each focusing on critical aspects such as human rights, the entrenchment of a narcotics economy within the war-torn nation, and the indispensable contribution of civil society organizations in navigating the path toward resolution and rebuilding. Each of these discussions brought together a diverse range of experts, policymakers, and stakeholders, fostering a collaborative environment where innovative solutions could be proposed and debated.

Highlighting the tour was the significant participation in the 54th Human Rights Council side event in Geneva, under the revealing theme, “Reshaping Syria’s Future: Examining the Roles of Trade Unions, Student Unions, and NGOs in Supporting Human Rights.” This event, a collaborative effort orchestrated by the Syrian Forum and generously sponsored by the EU Delegation to the United Nations, illuminated the troubling strategies employed by the Syrian regime. Notably, it delved into the regime’s manipulative methods of stifling opposition and free speech, exerting control over societal institutions to maintain power and silence dissenting voices.

The session in Geneva was a sounding board for expressing concerns regarding the Syrian government’s ongoing human rights violations and offered an international platform for discussing the potential of various societal sectors to contribute to the nation’s future. Trade unions, student bodies, and non-governmental organizations (NGOs) represent significant societal pillars that, if empowered and supported, could play substantial roles in a new, more hopeful chapter for Syria. Their potential to foster a culture that upholds human rights, promotes education, and supports economic development is invaluable in any post-conflict reconstruction scenario.

Moreover, the Syrian Forum USA, in a productive partnership with The Atlantic Council’s Syria Project and the New Lines Institute, initiated an insightful public conversation regarding the Assad regime’s dependence on a “narco-economy.” This discussion specifically tackled the U.S. strategy aimed at disrupting the trade of Captagon — an amphetamine-type stimulant known to be a substantial revenue stream for the regime. The discourse concluded with a strong consensus calling for a holistic strategy that goes beyond mere disruption. Experts and participants underscored the urgency of integrating criminal accountability measures to tackle this issue effectively, reflecting a profound understanding that the narcotics trade is not just an economic issue, but one deeply entwined with the ongoing violations of human rights and the perpetuation of conflict.

The advocacy tour was further characterized by a series of strategic engagements with international representatives at the UN headquarters in Geneva, as well as with various officials within the U.S. government in Washington, D.C. These high-level conversations focused on themes of humanitarian aid, continuous human rights violations, and the pressing necessity for enhanced support in critical sectors such as education inside Syria. The discussions were marked by frank exchanges and the sharing of insights on the ground realities, offering a comprehensive view of the challenges and potential pathways to alleviating the suffering of the Syrian people.

One of the prominent figures leading these discussions was Ghassan Hitto, the CEO of the Syrian Forum. Hitto passionately argued for direct assistance to Syrian humanitarian organizations, effectively eliminating the need for international intermediaries that often slow down the delivery of aid. This position resonated during meetings with U.S. officials, including the Deputy Assistant Secretary of State for Near Eastern Affairs and representatives from the National Security Council. Here, the delegation made a compelling case for expanded American backing for stability programs in Syria, emphasizing that bolstering education, healthcare, and economic opportunity were not merely acts of charity but strategic investments in regional stability and global security.

As the tour reached its conclusion, the delegation engaged in crucial talks with permanent missions of Security Council members, zeroing in on the worsening situation in northern Syria, especially in Idlib, one of the last opposition strongholds. These discussions were a stark reminder of the dire circumstances faced by civilians, particularly the threats of displacement, food insecurity, and violence. The Syrian Forum USA utilized these engagements to advocate vigorously for more substantial, direct support to address the spiraling humanitarian needs, aiming to foster conditions conducive to stability and eventual peace in the region.

The advocacy tour, in essence, was a manifestation of the Syrian Forum USA’s unwavering commitment to elevating the Syrian crisis to the highest rungs of international discourse. It underscored the organization’s dedication to not just highlighting the multifaceted humanitarian needs but also to advocating for tangible, robust support mechanisms that can provide a lifeline to the millions affected by the conflict. Through these efforts, the Syrian Forum USA reaffirms its stance as a proactive ambassador for the Syrian people, championing their cause and striving tirelessly to usher in a new era of peace, stability, and prosperity for a nation that has endured years of unspeakable hardships.

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