On May 17, 2021, the US Department of the Treasury’s Office of Foreign Assets Control designated three individuals and one entity with ties to the Islamic State of Iraq and Syria (ISIS) for their role in connecting ISIS with international donors and maintaining its access to the financial system in the Middle East. The designations of the individuals and entity were made pursuant to Executive Order 13224, as amended, for providing material support for, or goods or services to, ISIS. The timing of the sanctions were intended to coincide with the fourteenth meeting of the Counter ISIS Finance Group (CIFG), a group of nearly 70 countries and international organizations that jointly aim to restrict ISIS’s access to the international financial system and sources of revenue.
As a result these sanctions, all US property belonging to a designated individual or entity is blocked, and all transactions with US persons are generally prohibited. In addition, any entity in the US that is owned fifty percent or more by a sanctioned individual or entity is also blocked. Finally, persons who engage in certain transactions with a designated individual or entity may themselves be exposed to sanctions under EO 13224, and foreign financial institutions that knowingly conduct significant transactions for a designated person or entity could be prohibited from or subject to strict conditions when opening or maintaining a US correspondent or payable-through account.