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Financial Services Law Insights and Observations

OFAC sanctions ISIS financial facilitators in Syria and Turkey

Financial Crimes Department of Treasury OFAC Of Interest to Non-US Persons Sanctions OFAC Designations SDN List Syria

Financial Crimes

On May 17, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions pursuant to Executive Order 13224 against three individuals and one entity connected to the Islamic State of Iraq and Syria (ISIS) for allegedly helping ISIS access the financial system in the Middle East through a network of international donors. OFAC noted that these sanctions coincide with the fourteenth meeting of the Counter ISIS Finance Group, which coordinates efforts to isolate ISIS from the international financial system and eliminate revenue sources. As a result of the sanctions, all property and interests in property belonging to the sanctioned persons, and “any entities that are owned, directly or indirectly, 50 percent or more” by them that are subject to U.S. jurisdiction are blocked and must be reported to OFAC. OFAC’s announcement further noted that OFAC regulations “generally prohibit” U.S. persons from participating in transactions with the designated persons unless exempt or otherwise authorized by a general or specific license, and warned foreign financial institutions that if they knowingly facilitate significant transactions for any of the designated persons, they may be subject to U.S. correspondent account or payable-through account sanctions.