Overview

Khalifa Muhammad Turki al-Subaiy is an internationally designated terrorist financier and facilitator based in Qatar. He has allegedly funneled hundreds of thousands of dollars to al-Qaeda senior leaders in South Asia, including 9/11 mastermind Khalid Sheikh Mohammed. Subaiy has also funded the transit of al-Qaeda recruits to South Asia for terrorist training.“Treasury Designates Gulf-Based al Qaida Financiers,” U.S. Department of the Treasury, June 5, 2008, http://www.treasury.gov/press-center/press-releases/Pages/hp1011.aspx. In October 2014, a Telegraph report alleged that Subaiy was funding al-Qaeda-linked terrorism in Iraq and Syria.Robert Mendick, “Banker who financed 9/11 mastermind now funding terrorists in Syria and Iraq,” Telegraph, October 4, 2014, http://www.telegraph.co.uk/news/worldnews/middleeast/syria/11140190/Banker-who-financed-911-mastermind-now-funding-terrorists-in-Syria-and-Iraq.html.

Subaiy was a one-time employee of Qatar’s Central Bank, and reportedly one of Qatar’s “senior state employees” as of 2007.David Andrew Weinberg, “Qatar and Terror Finance Part 1: Negligence,” Foundation for Defense of Democracies, December 2014, 16, https://www.defenddemocracy.org/content/uploads/publications/Qatar_Part_I.pdf. According to the U.N. Security Council, Subaiy began financing al-Qaeda leaders in South Asia in the mid-2000s. In January 2008, the Bahrain High Criminal Court convicted Subaiy in absentia on charges of terrorist financing. Subaiy was arrested in Qatar in March 2008 and served a six-month prison sentence. After his release, Subaiy allegedly reconnected with Middle East-based al-Qaeda financiers and resumed funding for the terror group.“QDi.253KHALIFA MUHAMMAD TURKI AL-SUBAIY,” U.N. Security Council, last updated February 19, 2015, https://www.un.org/sc/suborg/en/sanctions/1267/aq_sanctions_list/summaries/individual/khalifa-muhammad-turki-al-subaiy;
“Consolidated U.N. Security Council Sanctions List,” U.N. Security Council, updated December 27, 2016, https://scsanctions.un.org/fop/fop?xml=htdocs/resources/xml/en/consolidated.xml&xslt=htdocs/resources/xsl/en/consolidated.xsl.

As of early 2011, Subaiy had funneled hundreds of thousands of dollars to senior al-Qaeda leaders in Pakistan.“Treasury Designates Twelve Foreign Terrorist Fighter Facilitators,” U.S. Department of the Treasury, September 24, 2014, http://www.treasury.gov/press-center/press-releases/Pages/jl2651.aspx. In mid-2012, Subaiy transferred hundreds of thousands of dollars intended for al-Qaeda leaders with the help of al-Qaeda financier Ashraf Muhammad Yusuf Uthman Abd al-Salam.“Treasury Designates Twelve Foreign Terrorist Fighter Facilitators,” U.S. Department of the Treasury, September 24, 2014, http://www.treasury.gov/press-center/press-releases/Pages/jl2651.aspx. In 2013, Subaiy solicited donations over Facebook for a fundraising campaign for Syria headed by U.S.-designated al-Qaeda-financier Sa’d bin Sa’d Muhammad Shariyan Al Ka’bi.“Use of Social Media by Terrorist Fundraisers & Financiers,” Camstoll Group, April 2016, 9, https://www.camstoll.com/wp-content/uploads/2016/04/Social-Media-Report-4.22.16.pdf. By October 2014, the Telegraph reported that Subaiy was continuing to fundraise for Islamists in Iraq and Syria, despite being the subject of U.S. and U.N. sanctions.Robert Mendick, “Banker who financed 9/11 mastermind now funding terrorists in Syria and Iraq,” Telegraph, October 4, 2014, http://www.telegraph.co.uk/news/worldnews/middleeast/syria/11140190/Banker-who-financed-911-mastermind-now-funding-terrorists-in-Syria-and-Iraq.html.

The U.N. Security Council added Subaiy to its Al-Qaida Sanctions List in October 2008.“QDi.253 KHALIFA MUHAMMAD TURKI AL-SUBAIY,” U.N. Security Council, last updated February 19, 2015, https://www.un.org/sc/suborg/en/sanctions/1267/aq_sanctions_list/summaries/individual/khalifa-muhammad-turki-al-subaiy. Nonetheless, Subaiy continued to access his bank accounts in Qatar through at least 2013, according to a June 2019 Wall Street Journal report. The report found that the United Nations permitted Subaiy and others on its sanctions list to access their bank accounts for so-called basic necessities. Subaiy reportedly took out up to $10,000 a month from frozen accounts.Ian Talley and Bradley Hope, “Accused Terrorists Use Loopholes to Tap Frozen Funds,” Wall Street Journal, June 19, 2019, https://www.wsj.com/articles/accused-terrorists-use-loopholes-to-tap-frozen-funds-11560977005. The revelation prompted international calls for the United Nations to fix the loopholes that allow for designated individuals to access financial systems with U.N. approval.“Terror group funding loophole must be closed,” The National, June 20, 2019, https://www.thenational.ae/opinion/editorial/terror-group-funding-loophole-must-be-closed-1.877040.

The United Nations amended the sanctions against Subaiy on March 23, 2021, to include updated passport and location information.“Security Council ISIL (Da’esh) and Al-Qaida Sanctions Committee Amends Eight Entries on Its Sanctions List,” United Nations, March 23, 2021, https://www.un.org/press/en/2021/sc14473.doc.htm. The Security Council removed Subaiy from its designations list on September 6, 2021, after receiving a legal request from Subaiy to delist him. The delisting nullified the U.N. assets freeze, travel ban, and arms embargo against Subaiy.“Security Council ISIL (Da’esh) and Al-Qaida Sanctions Committee Removes One Entry from Its Sanctions List,” United Nations, September 6, 2021, https://www.un.org/press/en/2021/sc14622.doc.htm. The United Kingdom lifted its sanctions on Subaiy the following day.Financial Sanctions Notice, U.K. Office of Financial Sanctions Implementation – HM Treasury, September 7, 2021, https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1015669/Notice_ISIL__Da_esh__and_Al-Qaida_070921.pdf. The European Union lifted its sanctions against Subaiy on September 9, 2021.“COMMISSION IMPLEMENTING REGULATION (EU) 2021/1460 of 9 September 2021,” EUR-Lex, September 9, 2021, https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32021R1460&qid=1638199969002. Subaiy remains designated in the United States.

Despite the international sanctions against him, Subaiy also continued to post to social media through at least 2016. Images of him driving sports cars and holding a lion on a leash appeared on his Facebook, Twitter, and Instagram accounts. A 2016 report by the Camstoll Group found that Subaiy also used the social media platforms “to communicate with followers and endorse fundraising campaigns….”Khaled Yacoub Oweis, “Suspected Al Qaeda financier impervious to its austere creed,” The National, June 20, 2019, https://www.thenational.ae/world/suspected-al-qaeda-financier-impervious-to-its-austere-creed-1.877109; Jaber Al Joodi, “Who is Khalifa al-Subaiy, former banker named among Qatar-linked terrorists?” Al Arabiya, June 10, 2017, https://english.alarabiya.net/en/features/2017/06/10/Who-is-Khalifa-al-Subaiy-who-is-named-among-Qatar-linked-terrorists-.html. The accounts have since been deleted as of June 2019.