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Anti-ISIS coalition emphasizes international cooperation
On June 16, the Counter ISIS Finance Group (CIFG) of the Global Coalition to Defeat ISIS released a joint statement by the CIFG co-leads (the US, Italy, and Saudi Arabia), which coordinates efforts to isolate the Islamic State of Iraq and Syria (ISIS) from the international financial system and eliminate its revenue sources. CIFG held its eighteenth meeting on June 7, and during the meeting attendees discussed ISIS’s presence in Africa and partner countries presented on actions taken to disrupt ISIS financing. The presentations also “demonstrated how coordinated action and information-sharing among states, non-governmental organizations (NGOs), and the private sector amplify the impact of law enforcement investigations, targeted sanctions, prosecutions, and other measures against ISIS financing networks.” The CIFG co-leads also mentioned that international cooperation has been vital in disrupting ISIS transactions outside of the formal financial system especially, amongst other things, amid the increasing use of virtual assets and mobile payment systems. CIFG members and observers are seeking, among other things: (i) support from counterterrorism partners, NGOs, and the private sector to increase information sharing; (ii) cooperation from countries prone to exploitation by ISIS financers; (iii) to assist vulnerable jurisdictions in their efforts against money laundering and terrorism financing; (iv) to urge Global Coalition members, particularly in Africa, to support their military to combat ISIS insurgency; and (v) to assist in a risk-based approach to implementing effective regulations, especially in the case of mobile payment platforms and virtual asset service providers. With a focus on international cooperation, CIFG members said they will continue to closely work with counterterrorism partners to disrupt ISIS funding sources and methods.
OFAC sanctions individuals and entities tied to ISIS
On January 5, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions pursuant to Executive Order 13224 against a key financial facilitation network of the Islamic State of Iraq and Syria (ISIS), which includes four individuals and two entities in Türkiye who are connected to the group’s recruitment and financial transfers to and from Iraq and Syria. According to OFAC, the designated network has “played a key role in money management, transfer, and distribution for ISIS in the region.” The Turkish Ministry of Treasury and Finance, in collaboration with the Ministry of Interior, also implemented an asset freeze against members of this 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 designated individuals or entities may themselves be exposed to secondary sanctions, OFAC warned, adding that “OFAC 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 has knowingly conducted or facilitated any significant transaction on behalf of a Specially Designated Global Terrorist (SDGT).”
Counter ISIS Finance Group wants group isolated from international financial system
On November 18, 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 seventeenth meeting on November 8-9 to discuss ongoing efforts to combat ISIS financing worldwide. During the meeting, attendees discussed ISIS financing in the Middle East, Europe, Africa, and South and Southeast Asia, as well as “key systemic vulnerabilities in the global anti-money laundering and countering the financing of terrorism (AML/CFT) regime.” CIFG noted that ISIS facilitators prefer informal funds transfer methods, and to a lesser degree, virtual asset service providers most likely “because they offer anonymity, lack oversight across many jurisdictions, charge relatively low service fees, and often conduct quicker transactions than banks and registered money services businesses.” Attendees also exchanged case studies of recent investigations and prosecutions, and discussed other efforts to implement AML/CFT reforms to disrupt ISIS fundraising and financial facilitation networks. With a focus on international cooperation, CIFG members said they will continue to closely work with counterterrorism partners to disrupt ISIS funding sources and methods.
OFAC sanctions individuals and entities tied to ISIS
On November 7, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions pursuant to Executive Order 13224 against four members of an Islamic State of Iraq and Syria (ISIS) cell operating in South Africa, along with eight companies owned, controlled, or directed by the individuals in the ISIS cell. According to OFAC, the individuals provided technical, financial, or material support to the terrorist group. As a result of the sanctions, all property and interests in property belonging to the sanctioned individuals and entities, and of “any entities that are owned, directly or indirectly, 50 percent or more by them, individually, or with other blocked persons” that are subject to U.S. jurisdiction are 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 designated individuals or entities may themselves be exposed to designation, OFAC warned, adding that foreign financial institutions that knowingly conduct or facilitate significant transactions to any of the sanctioned persons could also be subject to U.S. sanctions.
OFAC sanctions terrorist weapons trafficking network tied to ISIS-Somalia
On November 1, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions pursuant to Executive Order 13224 against the Islamic State in Somalia (ISIS-Somalia) — marking the first time this affiliate of the Islamic State of Iraq and Syria (ISIS) is being designated. The action follows designations taken by OFAC earlier in the month against a network of financial facilitators who hold leadership roles and are key interlocutors between the group and local companies in Somalia (covered by InfoBytes here). According to OFAC, the designated persons serve as “critical nodes for a weapons trafficking network that is closely integrated with ISIS-Somalia,” and maintain “strong ties to al-Qa’ida in the Arabian Peninsula (AQAP) and al-Shabaab.” Addressing the significance of the sanctions, Under Secretary of the Treasury for Terrorism and Financial Intelligence Brian E. Nelson said “[t]oday, we take direct aim at the networks funding and supplying both ISIS-Somalia and al-Shabaab that support their violent acts. The involvement of those designated today in other criminal activity, including piracy and illegal fishing, demonstrates the extent of ISIS-Somalia’s integration with illicit networks and other terrorist organizations operating in the region.” “Treasury is committed to working with partners in the region to disrupt the financing of ISIS and al-Shabaab,” Nelson said.
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, OFAC warned, adding that foreign financial institutions that knowingly facilitate significant transactions or provide significant financial services to any of the sanctioned persons could also be subject to U.S. sanctions.
Counter ISIS Finance Group continues efforts to isolate ISIS from international financial system
On May 17, the U.S. Treasury Department announced the release of a joint statement by members of 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 sixteenth meeting on May 9 to discuss ongoing efforts to combat ISIS financing worldwide. According to the statement, the Coalition is focusing “on disrupting international ISIS funds transfers and dismantling ISIS finance networks that support extremist activities, including terrorist attacks, militant recruitment, and promotion of violent ideology.”
During the meeting, participants discussed that, despite having access to at least 25 million U.S. dollars in reserves, ISIS Core in Syria and Iraq is struggling to meet its financial obligations, as its expenditures exceed its income. CIFG also noted that Africa has emerged as a center of gravity for ISIS, and “the branches and networks in Africa generally have precarious finances and typically rely on local fundraising schemes.” CIFG further stressed the importance to “remain vigilant” to “deepen our understanding of ISIS’s financial operations, emerging financial threats, and activities.”
Counter ISIS Finance Group continues efforts to isolate ISIS from international financial system
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.”
Terrorist Financing Targeting Center designates ISIS-affiliated financial facilitators and money services businesses
On July 15, the U.S. Treasury Department announced that the seven member nations of the Terrorist Financing Targeting Center (TFTC) have jointly designated six targets affiliated with the Islamic State of Iraq and Syria (ISIS), including three key money services businesses. Four targets are designated for providing “a critical financial and logistical lifeline to ISIS, its branches, and its global facilitation networks,” while two targets are designated for “abus[ing] the goodwill of the international community under the auspices of charitable giving to facilitate the transfer of funds for and to support the activities of ISIS’s branch in Afghanistan, ISIS-Khorasan (ISIS-K).” Since 2017, the participating TFTC members—Saudi Arabia, Bahrain, Kuwait, Oman, Qatar, the United Arab Emirates, and Treasury’s Office of Foreign Assets Control (OFAC)—have issued five rounds of joint designations against 60 terrorist targets globally, in an effort to challenge ISIS’s ability to finance its operations through money service businesses and charities operating under false pretenses.
As a result of the sanctions, “all property and interests in property of these targets that are or come within the United States or in the possession or control of U.S. persons must be blocked and reported to OFAC.” OFAC noted that its regulations “generally prohibit all dealings by U.S. persons or within the United States that involve any property or interests in property of blocked persons.” OFAC further warned that persons that engage in transactions with one of the designated individuals maybe be exposed to sanctions or subject to an enforcement action. Additionally, foreign financial institutions that knowingly facilitate significant transactions to the designated entities may be subject to prohibitions or strict conditions by OFAC.