On November 1, 2022, the US Department of the Treasury’s Office for Foreign Assets Control designated 8 individuals and 1 entity who are critical members of a weapons trafficking network that is closely integrated with of the Islamic State in Somalia (“ISIS-Somalia”), an affiliate of the Islamic State of Iraq and Syria (“ISIS”). ISIS-Somalia, which reportedly pledged allegiance to ISIS in 2015, was designated by the State Department in 2018 as Specially Designated Global Terrorists (“SDGTs”) under Executive Order 13224.
According to OFAC, these weapons trafficking networks operate primarily between Yemen and Somalia and have strong ties to al-Qa’ida in the Arabian Peninsula and al-Shabaab. These designations come approximately 2 weeks after OFAC designated of a network of financial facilitators and weapons smugglers linked to al-Shabaab on October 17, 2022. Al-Shabaab also recently claimed responsibility for a bombing in Mogadishu that injured 300 civilians and claimed 100 lives on October 29, 2022. OFAC reports that several of the new designees have connections to al-Shabaab and either sold weapons to the group or were active al-Shabaab members. The new designations were imposed by OFAC pursuant to Executive Order 13224, as amended, for having materially assisted, sponsored or provided financial support for ISIS-Somalia.
As a result these designations, all property and interests in property of the 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 50 percent or more by a designated person or entity are also blocked, and foreign financial institutions that knowingly conduct significant transactions for the designated entities risk exposure to sanctions.