InfoBytes Blog
OFAC sanctions financial facilitators
On October 17, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions, pursuant to Executive Order (E.O.) 13224, against a network of financial facilitators who hold leadership roles and are key interlocutors between the group and local companies in Somalia. According to OFAC, the network has engaged in weapons procurement, financial facilitation, and recruitment activities. OFAC further noted that in addition to being leaders within the designated network, these facilitators have had direct contact with other previously designated officials in the network. Concurrent with OFAC’s designations, the U.S. State Department designated five of the network’s leaders pursuant to E.O. 13224, as amended, for their leadership roles within the designated network. As a result of the sanctions, all property and interests in property belonging to the sanctioned persons subject to U.S. jurisdiction are blocked and must be reported to OFAC. Additionally, “any entities that are owned, directly or indirectly, 50 percent or more by one or more blocked persons are also blocked.” U.S. persons are also generally prohibited from engaging in any dealings involving the property or interests in property of blocked or designated persons. Persons that engage in certain transactions with the individuals or entities designated today may themselves be exposed to designation. Additionally, OFAC warned that engaging with the designated individuals can impose risk of secondary sanction. OFAC also stated that it “can prohibit or impose strict conditions on the opening or maintaining in the United States of a correspondent account or a payable-through account of a foreign financial institution that knowingly conducts or facilitates any significant transaction, or provides significant financial services, for any [Specially Designated Global Terrorist].”