September 10, 2019

New terrorism designations and amended Executive Order

The Office of Foreign Assets Control of the US Department of the Treasury announced the amendment of Executive Order 13224, Modernizing Sanctions to Combat Terrorism, on September 10, 2019.  The amended E.O. 13224 allows the government to target leaders of terrorist groups and individuals who participate in terrorist training more efficiently.  It also provides for secondary sanctions against foreign financial institutions that have knowingly conducted or facilitated significant financial transactions on behalf of a sanctioned person.  It authorizes the US Department of the Treasury to prohibit foreign financial institutions that have knowingly conducted or facilitated a significant transaction with a Specially Designated Global Terrorist (SDGT) from opening or maintaining a correspondent account or payable-through account in the US.

Using the amended criteria, OFAC designated 15 individuals and entities affiliated with Hamas, ISIS, al-Qu’aida and the Islamic Revolutionary Guard Corps-Qods Force.  The designated persons include the Redin Exchange, a Turkey-based entity that has facilitated the transfer of millions of dollars to Hamas, its operational arm, the Izz-Al-Din Al-Qassam Brigades, and the IRGC-QF; a Turkey-based jewelry company involved in a scheme to convert gold into cash for Isis, and individuals based in Brazil, the Maldives, and the Phillippines.

As a result of the designations, all US property of the designated persons is blocked, and dealings by US persons or persons in the US that involve the property or interests of blocked or designated persons are generally prohibited.  Pursuant to the amended 13224, all SDGTs are subject to secondary sanctions for foreign financial institutions.

US Dept. of the Treasury press release | E.O. 13224