On January 5, 2023, the US and Turkish governments took joint action imposing sanctions targeting four individuals and two entities established to be associated with the Islamic State of Iraq and Syria (“ISIS”) financial facilitation network. See here for US action and here for Turkish action.
The appointment targets the Islamic State group’s head of foreign financing, Abd Al Hamid Salim Ibrahim Ismail Brukan al-Khatuni, and its network which is coordinated by his sons. A US Department of the Treasury press release explains that this network plays a key role in the management, transfer, and distribution of money for ISIS in the region.
The sanctions were imposed by the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”), Turkey’s Ministry of Finance and Treasury, and Turkey’s Ministry of Interior. OFAC adds these parties to its List of Specially Designated Citizens or Blocked Persons (“SDN List”), which essentially disconnects these parties from the US financial system and transactions involving US communications. The Ministry of Finance and Interior of Türkiye implemented an asset freeze on the targeted parties.
These developments demonstrate an increasing level of international involvement and coordination in sanctions policy, including by countries such as Türkiye, which has not traditionally used sanctions as a policy tool on a routine basis like some countries. The authors acknowledge Ryan Orange’s assistance in the preparation of this blog post.
Ms. Contini focuses her practice on export controls, trade sanctions and anti-boycott laws. This includes advising US and multinational companies on trade compliance programs, risk assessments, licensing, review of proposed transactions, and enforcement issues. Ms. Contini works regularly with companies in a variety of industries, including the pharmaceutical/medical device, oil and gas, and nuclear sectors.
