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Financial Services Law Insights and Observations

OFAC sanctions ISIS facilitators

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

Financial Crimes

On March 1, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions pursuant to Executive Order 13224 against four Islamic State of Iraq and Syria (ISIS) and ISIS-Mozambique financial facilitators based in South Africa for allegedly supporting the transfer of funds from the top of the ISIS hierarchy to branches across Africa or for serving as leaders of ISIS cells. As a result of the sanctions, all property and interests in property of the designated individuals within U.S. jurisdiction must be blocked and reported to OFAC. OFAC further noted that its regulations “generally prohibit” U.S. persons or persons within the United States from participating in transactions with the designated persons and warned foreign financial institutions that if they knowingly facilitate significant transactions for any of the designated individuals, OFAC may prohibit or impose strict conditions on the opening or maintaining of a U.S. correspondent account or payable-through account.