On March 25, 2022, the US Department of the Treasury’s Office of Foreign Assets Control designated a six-member cell of Nigeria-based terrorist group Boko Haram pursuant to EO 13224 – a cell that has been operating in the United Aram Emirates (UAE) to raise funds for insurgents in Nigeria. Boko Haram was designated by the US State Department as Foreign Terrorist Origination and a Specially Designated Global Terrorist in 2013. The US designations were imposed just months after the arrest, prosecution and designation of these individuals by the Emirati government in September 2021 in an effort to disrupt the flow of funds to Boko Haram. OFAC reports that the UAE Federal Court of Appeals convicted all six individuals for transferring $782,000 from Dubai to Boko Haram in Nigeria, resulting in two who were sentenced to life in prison for violating UAE anti-terrorism laws and four who were sentenced to ten years in prison to be followed by deportation.
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, Foreign financial institutions that engage in certain transactions with today’s designees risk 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).