On July 15, 2020, the Terrorist Financing Targeting Center (TFTC), partnered with the US Department of the Treasury’s Office of Foreign Assets Control, to designate six targets affiliated with the Islamic State of Iraq and Syria (ISIS) for their role in the facilitation of funds in support of ISIS. The TFTC sanctioned four entities and two individuals from Syria, Turkey and Afghanistan for supporting the transfer of funds through a global network of money services businesses and false charities, to provide hundreds of thousands of dollars in liquidity to ISIS fighters and leadership. The TFTC, made up of seven member nations – Saudi Arabia, Bahrain, Kuwait, Oman, Qatar and United Arab Emirates – was formed in 2017 to fight terrorism by coordinating disruptive actions, sharing financial intelligence, and increasing members’ ability to target activities that pose a national security threat.
Five of the TFTC designees were previously sanctioned by OFAC in November of 2019, pursuant to Executive Order 13224, as amended by E.O. 13886, that targets individuals and entities that provide material, financial or technological services, to support of terrorists for terrorist organizations. One of the TFTC targets was sanctioned by OFAC in April 2019, before E.O. 13224 was amended by E.O. 13886.
As a result of the joint designations, all US property belonging to these individuals and entities is blocked, and all transactions in the US are generally prohibited. Furthermore, any person who transacts with any jointly designated person or entity may themselves be exposed to sanctions. With regards to the designations made pursuant to E.O. 13224, as amended by E.O. 13886, there are secondary sanctions, that allow OFAC to prohibit the opening of US correspondent accounts or payable-through accounts by any foreign financial institution that knowingly facilitates a transaction for persons sanctioned under the Executive Order.