On January 5, 2022, the US Department of the Treasury’s Office of Foreign Assets Control designated four individuals and two entities in Türkiye for being members of a key financial facilitation network that has enabled the Islamic State of Iraq and Syria (“ISIS”) to recruit and process financial transfers to and from Iraq and Syria. The Turkish Ministry of Treasury and Finance and the Ministry of Interior have concurrently implemented an asset freeze against this network’s members. The OFAC designations were imposed pursuant to Executive Order 13224, as amended, which targets terrorists, terrorist organizations, their leaders, and those who support terrorists or acts of terrorism.
According to OFAC, Abd Al Hamid Salim Ibrahim Ismail Brukan al-Khatuni was designated for playing a key role in ISIS money management, transfer, and distribution. OFAC reports that he has been instrumental in ISIS financing since 2016 when he moved to Turkiye to manage ISIS’s financial network and join an ISIS recruitment cell. OFAC also designated Brukan al-Khatuni’s two sons who reportedly work as part of their father’s financial network and two entities that are owned or controlled by Brukan al-Khatuni, including a money services business that was rebranded by Brukan al-Khatuni as Wado Alrrafidayn for Foodstuffs, and Sham Express, which has been used by ISIS affiliates to transfer funds for the group. ISIS financial facilitator Lu’ay Jasim Hammadi al-Juburi was designated for using Sham Express to transfer money on behalf of ISIS between Türkiye, Syria, and Iraq.
As a result of 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.