On January 30, 2024, the US Department of the Treasury’s Office of Foreign Assets Control designated three individuals who allegedly supported the Islamic State of Iraq and Syria (“ISIS”) by providing cybersecurity training to ISIS leadership or transferring funds to ISIS-affiliated persons. According to OFAC, two of the designees were Egyptian nationals who were cybersecurity experts that not only provided technical training to ISIS leaders but also enabled their use of virtual currency and media-based recruitment efforts. The third designee was a ISIS financial facilitator based in Türkiye who allegedly received multiple money transfers from ISIS supporters in 2020 and distributed the funds to ISIS-affiliated individuals in Syria. OFAC reported that the designations were issued to coincide with the 19th meeting of the Counter ISIS Finance Group (“CIFG”), a working group comprised of more than 80 countries and international organizations that recently met to discuss the disruption of ISIS financing networks around the world.
The designations were imposed pursuant to Executive Order 13224, as amended, which targets terrorist groups and their supporters. As a result of these designations, all property and interests in property of the designated person 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 a designated person. Entities owned 50 percent or more by one or more blocked persons are also blocked.