On May 9, 2022, the Department of the Treasury’s Office of Foreign Asset Control designated a network of five financial facilitators who funded Islamic State of Iraq and Syria (ISIS) activities and played a key role in facilitating the travel of ISIS extremists. OFAC reports that the sanctions were timed to coincide with the 16th meeting of the Counter ISIS Finance Group (CIFG) of the Global Coalition to Defeat ISIS, a group comprised of nearly 70 countries and international organizations that coordinate efforts against ISIS financial support networks around the world. According to OFAC, this network of five individuals operated across Indonesia, Syria, and Turkey conducting financial transfers, a portion of which was used to smuggle children out of displacement persons camps in Syria and deliver them to ISIS foreign fighters as potential recruits. The five were designated by OFAC pursuant to Executive Order 13224, as amended, for providing financial support to ISIS or a designated member of ISIS.
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 financial institutions that knowingly facilitate any significant transactions on behalf of a Specially Designated Global Terrorist (SDGT).