On January 5, 2023, the US and Turkish governments took joint action imposed sanctions targeting four individuals and two entities determined to be associated with the financial facilitation network of the Islamic State of Iraq and Syria (“ISIS”). See here for the US action and here for the Turkish action.
The designations target the Islamic State group’s head of foreign financing, Abd Al Hamid Salim Ibrahim Ismail Brukan al-Khatuni, and his network coordinated by his sons. The US Treasury Department’s press release explains that this network played a key role in money management, transfer, and distribution for ISIS in the region.
The sanctions were imposed by the US Treasury Department’s Office of Foreign Assets Control (“OFAC”), the Turkish Ministry of Treasury and Finance, and the Turkish Ministry of Interior. OFAC added these parties to its List of Specially Designated Nationals or Blocked Persons (“SDN List”), essentially cutting these parties off from the US financial system and transactions involving a US nexus. Türkiye’s Treasury and Interior ministries implemented an asset freeze against the targeted parties.
This development points to the increasing levels of engagement and international coordination on sanctions policy, including by countries like Türkiye, which have not traditionally used sanctions as a policy tool as routinely as some nations.The authors acknowledge the assistance of Ryan Orange with the preparation of this blog post.
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Sunny Mann
Sunny Mann is the global chair of our International Trade Practice Group. He is a partner based in the London office, and has also worked in our Firm's Washington DC, New York, Sydney and Hong Kong offices.
Sunny advises clients (including numerous FTSE 100 and Fortune 100 businesses) on compliance and investigations with respect to export controls, trade sanctions and anti-bribery rules. Sunny is ranked as a Band 1 practitioner by both Legal 500 and Chambers, and was described as "excellent, with a calm and very practical approach”. Legal 500 most recently noted that Baker McKenzie “have a great team led by Sunny Mann, who has a reputation for being a strong and fair leader with fantastic people management skills to complement his undoubted trade controls expertise”.
Sunny also chairs our Geopolitical Risks Taskforce and oversaw our Firm’s support to clients responding to Russia’s invasion of Ukraine. The team was at the forefront of the market, having advised around one quarter of each of the Fortune 100, FTSE 100, CAC 40 and DAX 30 communities.
Sunny is a Visiting Professor at King’s College, London (teaching sanctions on the LLM course) and was for 15 years a Visiting Professor at the College of Europe, the leading institute for post-graduate European studies, where he taught an LLM course on Corporate Compliance.
Sunny has also served as a board member and trustee at Battersea Dogs and Cats Home, one of the oldest animal shelters.
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Kerry B. Contini
Kerry Contini is a partner in the Firm's International Trade practice and Global Sanctions Investigations group, specializing in sanctions and export controls. She helps multinational companies navigate these ever-changing rules and guides them through investigations when compliance issues occur. Kerry provides strategic advice on related geopolitical risks, human rights, and supply chain issues.
Kerry has been ranked by Chambers Global and Chambers USA, with clients highlighting that "her advice and solutions are business-focused" and that she is "very practical and easy to work with." Legal 500 reported a client as stating that "Kerry is thoughtful, practical, efficient, and has really invested in getting to know our business and our team."
Kerry has been quoted by the Wall Street Journal, Global Investigations Review, Bloomberg Law, the National Law Journal and Asian Legal Business. She is an editor of the Firm's Global Supply Chain Compliance Blog and is a regular contributor to the Firm's Global Sanctions & Export Controls Blog.
Kerry is passionate about inclusion and diversity and is involved in the BakerWomen DC and regional leadership. She has maintained an active pro bono practice throughout her career at Baker McKenzie, primarily focusing on public international law, animal advocacy and election protection.
Kerry has been with Baker McKenzie since she was a summer associate in 2005. She started as an associate in 2006.
