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Financial Services Law Insights and Observations

Counter ISIS Finance Group continues efforts to isolate ISIS from international financial system

Financial Crimes Of Interest to Non-US Persons OFAC Sanctions OFAC Designations Department of Treasury OFAC ISIS

Financial Crimes

On December 14, the U.S. Treasury Department announced the release of a joint statement by the Counter ISIS Finance Group (CIFG) of the Global Coalition to Defeat ISIS, which coordinates efforts to isolate the Islamic State of Iraq and Syria (ISIS) from the international financial system and eliminate revenue sources. CIFG held its fifteenth meeting on December 6-7 to discuss ongoing efforts to combat ISIS financing worldwide. According to the statement, the “Coalition is deepening and expanding cooperation to identify and disrupt ISIS finance networks around the world, while taking steps to strengthen oversight of financial systems and non-profit sectors in vulnerable jurisdictions to prevent their abuse by terrorist groups and their supporters.” During the meeting, participants discussed ISIS financing in Africa, the Middle East, and South Asia, as well as recent judicial and administrative enforcement actions. CIFG noted that while ISIS continues to rely on the use of informal money service businesses (e.g., cash couriers and charitable appeals made through internet platforms) to move funds across borders, authorities in several key countries have coordinated measures to disrupt these activities. CIFG noted that local virtual asset service providers’ compliance with anti-money laundering and countering the financing of terrorism standards have helped as well. CIFG further stressed the importance of “ongoing vigilance” to prevent ISIS’ abuse of non-profit organizations, and “encourage[d] counterterrorism partners to share their knowledge and experiences to strengthen our fight against ISIS financing and defend the international financial system from abuse by terrorists.”