Terrorist Financing Targeting Center Sanctions Network of ISIS-Linked Financial Facilitators and Money Services Businesses
July 15, 2020
Washington – Today, the seven member nations of the Terrorist Financing Targeting Center (TFTC) jointly designated six targets affiliated with the Islamic State of Iraq and Syria (ISIS). Three entities and one individual located in Turkey and Syria have provided a critical financial and logistical lifeline to ISIS, its branches, and its global facilitation networks. Additionally, an Afghanistan-based organization, Nejaat Social Welfare Organization, and the organization's director, Sayed Habib Ahmad Khan, abused 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). The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) designated these key ISIS financial facilitators in partnership with the other TFTC member states: the Kingdom of Saudi Arabia, the Kingdom of Bahrain, the State of Kuwait, the Sultanate of Oman, the State of Qatar, and the United Arab Emirates.
"The TFTC's momentous efforts over the past three years have maximized the disruption of terrorist financing around the world," said Treasury Secretary Steven T. Mnuchin. "The TFTC has brought the U.S. and its Gulf partners closer together to confront shared regional threats and build the lasting capacity to target terrorist financial networks wherever they operate."
Since its inception in 2017, the TFTC has issued five rounds of joint designations against over 60 terrorist individuals and entities spanning the globe. These designations targeted a wide range of terrorist organizations, including ISIS and its affiliates, al-Qa'ida, Iran's Islamic Revolutionary Guard Corps, Lebanese Hizballah, and the Taliban. Today's designations further challenge ISIS's ability to conceal its activities and finance its operations through key money services businesses and charities operating under false pretenses.
This action targets three significant money services businesses: al Haram Exchange, Tawasul Company, and al-Khalidi Exchange. These money services businesses have played a vital role in transferring funds to support Syria-based ISIS fighters and have provided hundreds of thousands of dollars of liquidity to ISIS leadership, including the now deceased, former ISIS finance emir Fawaz al Rawi, who was designated by the U.S. Department of the Treasury in December 2016. As of April 2019, ISIS members in Syria received instruction to conduct all financial transactions with al Haram Exchange. As of 2018, ISIS had used Tawasul Company, as well as multiple other companies in Syria and Western Europe, to transfer money among ISIS fighters. Additionally, as of late 2017, the operators of al-Khalidi Exchange knowingly assisted ISIS members with financial transfers, and in late 2016 al-Khalidi Exchange was the most important financial transfer office in the region, moving money to fund ISIS-held areas. The TFTC also designated Abd-al-Rahman 'Ali Husayn al-Ahmad al-Rawi (Abd-al-Rahman), who was selected by ISIS in 2017 to serve as a senior financial facilitator. Abd-al-Rahman was one of a few individuals who provided ISIS significant financial facilitation into and out of Syria. He entered into a secret business relationship with a Turkey-based individual who specialized in conducting large-sum hawala transfers from the Gulf, including funds intended for ISIS. This action represents a further setback to ISIS because of Abd-al-Rahman's significant influence within the terrorist group and his responsibility for external ISIS transfers.
The TFTC is also taking action against the Afghanistan-based Nejaat Social Welfare Organization (Nejaat) and its director, Sayed Habib Ahmad Khan. Nejaat has been used as a cover company to facilitate the transfer of funds and support the activities of ISIS-K. Nejaat collected donations on behalf of ISIS-K from individuals in the Gulf and the Levant, and the money was then transferred from the Gulf to Asia–via the banking system–where an ISIS-K coordinator would collect the transferred funds. Nejaat's offices in Kabul and Jalalabad then distributed the funds to ISIS-K commanders.
Five of these targets were previously designated by the U.S. Department of the Treasury pursuant to Executive Order 13224, as amended by Executive Order 13886, which targets terrorists and those who have, among other things, materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, terrorists. One target, Abd-al-Rahman, was designated in April 2019 before Executive Order 13224 was amended by Executive Order 13886. The TFTC, which was established in 2017, coordinates disruptive actions, shares financial intelligence information, and builds member state capacity to target activities posing national security threats to the TFTC members.
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's regulations generally prohibit all dealings by U.S. persons or within the United States (including transactions transiting the United States) that involve any property or interests in property of blocked persons. In addition, persons that engage in certain transactions with the individual jointly designated today may themselves be exposed to sanctions or subject to an enforcement action.
Furthermore, designation pursuant to Executive Order 13224, as amended by Executive Order 13886, carries secondary sanctions implications with respect to all Specially Designated Global Terrorists. OFAC can prohibit or impose strict conditions on the opening or maintaining in the United States of a correspondent account or payable-through account of a foreign financial institution that knowingly conducts or facilitates any significant transaction on behalf of any person whose property and interest in property are blocked pursuant to Executive Order 13224, as amended by Executive Order 13886.
Additional information on the U.S. designations of Tawasul Company, Nejaat Social Welfare Organization, and Sayed Habib Ahmad Khan.
Additional infoArmation on the U.S. designations of al Haram Exchange and al-Khalidi Exchange.
Additional information on Abd-al-Rahman 'Ali Husayn al-Ahmad al-Rawi.
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