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Financial Services Law Insights and Observations

OFAC, Turkey sanction terrorist financing facilitators

Financial Crimes Of Interest to Non-US Persons OFAC OFAC Sanctions OFAC Designations SDN List Turkey

Financial Crimes

On May 2, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced, pursuant to Executive Order 13224, a joint action with the Republic of Turkey to designate two financial facilitators of Syria-based terrorist groups. The terrorist groups have both been sanctioned by the U.S. and the United Nations. The action demonstrates OFAC’s continued cooperation with Turkey to restrict the financing of terrorist groups that perpetuate violence and instability throughout the region. According to the announcement, the Turkish Ministry of Treasury and Finance and the Turkish Ministry of Interior concurrently implemented an asset freeze against the sanctioned individuals. As a result of the sanctions, all property interests belonging to the sanctioned individuals and entities that are in the U.S. or in the possession or control of U.S. persons are blocked and must be reported to OFAC, as well as “any entities that are owned, directly or indirectly, 50 percent or more by them, individually, or with other blocked persons.” U.S. persons are generally prohibited from engaging in any dealings involving the property interests of blocked or designated persons, and persons that engage in certain transactions with the designated individuals may themselves be exposed to sanctions. OFAC further 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 conducted or facilitated any significant transaction on behalf of a Specially Designated Global Terrorist.”