Anti-terrorist Sanctions

OFAC announces anti-terrorist sanctions

On 10th September, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced the imposition of sanctions on 15 leaders, individuals, and entities affiliated with terrorist groups in accordance with the new Executive Order (E.O.) 13886, entitled “Modernizing Sanctions to Combat Terrorism,” which updates E.O. 13224. O.S. 13886 provides the Treasury and the Department of State with “new tools” for identifying and targeting sanctions.

Under this new executive order, foreign financial institutions are now subject to secondary sanctions, allowing OFAC to prohibit or impose strict conditions on the opening or maintenance in the U.S. of a correspondent account or guaranteed payment account by any foreign financial institution that knowingly facilitates a significant transaction for any “Specially Designated Global Terrorist” (SDGT) or for a person acting on behalf of or under the direction of, owns or is under the control of an SDGT.

As a result of the imposition of these new sanctions, all assets and interests in assets of sanctioned targets subject to U.S. jurisdiction are blocked and must be reported to OFAC. U.S. persons are also generally prohibited from conducting transactions with designated persons. Finally, OFAC cautions that persons conducting transactions with designated persons “may be subject to sanctions or enforcement action.”