Rahman Ravelli
Syedur Rahman Ulrich Schmidt

The UK’s first anti-terrorism sanctions conviction

Syedur Rahman and Ulrich Schmidt outline the case 

The director of a charity has become the subject of the UK’s first anti-terrorism sanctions conviction.

Aozma Sultana, 42, from Luton, had been sanctioned by the UK and the US Office of Foreign Assets Control (OFAC) for her links to an alleged Hamas-linked news network. She has been convicted of breaching the UK’s Counter Terrorism Regulations by failing to respond to multiple requests for information from the Office of Financial Sanctions Implementation (OFSI), following her designation in 2024.

Sultana was convicted at Westminster Magistrates’ Court, which heard she had been sanctioned by the UK government for allegedly providing financial support to Gaza Now, a media organisation that has been accused of supporting the Hamas and Palestinian Islamic Jihad terrorist groups. 

Sultana was asked to fill out a financial questionnaire after her designation, which included questions about her assets and sources of income in the UK. The questionnaire was received by OFSI a month later. It had “do not remember” as the answer written to almost all of the questions. Two further requests for information made by OFSI were not answered.

OFSI official Amelia Coyne told the court that the agency sends every sanctioned person a financial questionnaire to understand that person’s financial position. The agency can then issue licences allowing that person to carry out certain transactions. 

Sultana was arrested and questioned at Luton Police Station last November and was given another opportunity to provide the missing information. But she refused.

She chose not to give evidence at her trial. Her lawyer emphasised that Sultana had answered some of the questions on the financial questionnaire, including providing the names of two companies of which she was a director – Aakhirah and Al-Qureshi Executives – and the name of her mobile network provider. She had said that OFSI could obtain further information that she did not remember from “companies in the government” and from her phone, which was in police custody.

But the judge decided that the prosecution had proved “the requisite elements” of the offence. The judge added that Sultana had not fully filled in the questionnaire and her directing of OFSI to ask other government agencies and the police for the information did not discharge her from her obligation to comply with the requests for information.  

At the sentencing, which was six weeks after Sultana’s conviction, the judge noted that the information still had not been provided by her. The judge stated that the starting point for the offence would be a custodial sentence of 15 weeks. However, representatives for Sultana presented mitigating evidence, resulting in the judge sentencing Ms Sultana to 10 weeks imprisonment, suspended for 12 months. 

Four months ago, the Charity Commission began investigating Sultana’s suspected fundraising activities for Gaza Now. The regulator said it had “serious concerns” that funds allegedly raised for charitable purposes by the companies of which Sultana is a director may have been misappropriated.

Her sentencing shows that a hard stance is being taken in relation to such activities - and that a failure to respond can place individuals in serious trouble. Her conviction is not the only example of this stance: in April this year, OFSI imposed a penalty of £5,000 on Svarog Shipping & Trading Company Limited for failing to respond to an information request relating to an investigation into breaches of UK sanctions against Russia.

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Syedur Rahman
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Syedur Rahman is known for his in-depth experience of serious fraud, white-collar crime and serious crime cases, as well as his expertise in worldwide asset tracing and recovery, international arbitration, civil recovery, cryptocurrency and high-stakes commercial disputes.

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