On March 1, 2022, the US Department of the Treasury’s Office of Foreign Assets Control designated four South Africa-based financial facilitators of Islamic State of Iraq and Syria (ISIS) and ISIS-Mozambique (ISIS-M). According to OFAC, these individuals were designated pursuant to Executive Order 13224, as amended, for facilitating the transfer of funds from the top members of the ISIS hierarchy to branches across Africa or for serving as leaders in South African ISIS cells. OFAC reports that ISIS’s funds are derived from fundraising schemes that include theft, extortion and kidnapping for ransom against local populations across South Africa. Three of the newly-sanctioned individuals were designated under EO 13224 for providing material support to ISIS, and the fourth was designated for providing material support to ISIS-M.
As a result of these designations, all property and interests in property of today’s designees within the United States or within the possession or control of a US person are blocked, and US persons are generally prohibited from engaging in transactions involving the designated persons. In addition, entities owned fifty percent or more by one or more designated persons are also blocked. Pursuant to EO 13224, as amended, any party that engages in certain transactions risks exposure to secondary sanctions. OFAC can also prohibit or restrict the opening or maintenance of US correspondent accounts or payable-through accounts by foreign institutions that knowingly facilitate any significant transactions on behalf of a Specially Designated Global Terrorist (SDGT).