US, Turkey impose joint sanctions on ISIS funding network

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    On January 5, 2023, the U.S. and Turkish governments targeted four individuals and two entities determined to be associated with the Islamic State of Iraq and Syria (“ISIS”) financial facilitation network. , jointly imposed sanctions. See here for US actions and here for Turkey actions.

    The designation targets the Islamic State group’s head of foreign finance, Abd al-Hamid Salim Ibrahim Ismail Burkhan al-Hatuni, and his network coordinated by his sons. . The US Treasury Department press release explained that the network played a key role in his ISIS fund management, remittance and distribution in the region.

    The sanctions were imposed by the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”), the Turkish Ministry of Finance, and the Turkish Ministry of Interior. OFAC will add these parties to a list of specially designated nationals or blocked persons (the “SDN List”) and will keep these parties essentially out of transactions related to the U.S. financial system and the U.S. nexus. detached. Türkiye’s Ministry of Finance and Ministry of Interior implemented an asset freeze against the targeted officials.

    This development demonstrates a growing level of engagement and international coordination on sanctions policy, including in countries such as Turkey, which traditionally do not use sanctions as a policy tool on a daily basis as some do. .The authors would like to thank Ryan Orange for assistance in preparing this blog post.


    author
    Kelly B. Contini

    Kerry Contini is a partner in our international trade practice in Washington, DC. She advises companies on export control, sanctions, and related human rights and compliance issues for her chain of supply. She joined Mackenzie Baker as her associate in the summer of 2005 and began working as an associate in 2006. Kelly was ranked in her Up and Coming category for Export Controls and Trade Sanctions by Chambers Global (2022) and Chambers USA (2021). , the client emphasizes that “her advice and solutions are business-focused” and that she is “very practical and easy to work with.” Kelly was recognized by the Legal 500 as Baker She was an “outstanding” member of Mackenzie’s international trade team. Legal 500 reported one client: team. ” Kelley was recognized as a Global Leader in Trade and Customs – International Sanctions by Who’s Who Legal 2021. Kelley has written on export control and trade sanctions issues for many publications including WorldECR, The Export Practitioner and Ethisphere. She has filed with the U.S. International Trade Commission on pandemic-related supply chain issues Kerry has been cited by many publications, including Global Investigations Review and Asian Legal Business. Editor of the Global Supply Chain Compliance blog and a regular contributor to the blog and the company’s Sanctions and Export Control Updates blog.Kelly is Co-Chair of the Export Controls and Sanctions Section of the Women’s Association of International Trade. Kelly is a member of the Diversity and Inclusion Leadership of the Washington, DC office and a member of the BakerWomen Steering Committee.She has maintained an active pro bono activism throughout her career at Baker McKenzie and is a Pro Bono Director of the Washington, DC office. Co-Chair of the Leadership Team Kelly has worked on a wide range of pro bono issues, primarily public international law, animal advocacy, and electoral protection. Active member of the community animal law committee.



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