On July 28, 2020, the US Department of the Treasury’s Office of Foreign Assets Control announced the designation two Islamic State of Iraq and Syria (ISIS) financial supporters, pursuant to Executive Order 13224, as amended, that targets those who commit acts of terrorism and provide material support to terrorist groups. Faruq Hamud was sanctioned for operating a branch of the Tawasul hawala in the al Hawl Internally Displaced Persons camp in Syria, that provides financial support for ISIS members from payments received from outside of Syria. ‘Adman Muhammad Amin Al-Rawi was sanctioned for being an ISIS facilitator in Turkey.
These designations happen to coincide with the thirteenth meeting of the Counter ISIS Finance Group (CIFG), a coalition comprised of over 60 countries and international organizations, including the US, that work together to prevent ISIS’s efforts to access the international financial system and restrict its sources of revenue.
As a result of these 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 designated person may themselves be exposed to sanctions, and any foreign financial institution that knowingly conducts a transaction on behalf of a designated person, could be subject to US correspondent account or payable-through account sanctions.