On July 23, 2024, the U.S. Department of Treasury’s Office of Foreign Assets Control designated individuals associated with a network that supports Islamic State of Iraq and Syria (“ISIS”) operations and ISIS leaders on the African continent. According to OFAC, three individuals – Abubakar Swalleh, Zayd Gangat, and Hamidah Nabagala – were designated for serving as key financiers and trusted operatives of a network that ISIS leaders use to leverage affiliates in a variety of locations across Africa, including the Democratic Republic of the Congo (“DRC”), Mozambique, and Somalia, in order to coordinate terrorist attacks throughout the region. The designees have allegedly facilitated or trained ISIS members in the African region or engaged in the transfer of ISIS funds throughout Africa – funds that ISIS has historically collected through robberies and kidnapping for ransom operations. The funds have reportedly been used to finance ISIS recruiting and training efforts and terrorist activities, including the October 2021 Kampala bombing that killed one person and injured at least three others.
These sanctions were imposed pursuant to Executive Order 13224, as amended, which targets terrorist groups and their supporters. As a result of these designations, all property and interests in property of the designated persons within the United States or within the possession or control of a U.S. person are blocked, and U.S. persons are generally prohibited from engaging in transactions involving a designated person. Entities owned 50 percent or more by one or more blocked persons are also blocked.