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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 is a Partner in Baker McKenzie's London office and co-leads the UK Compliance and Investigations Practice, as well as the UK International Commercial and Trade Practice. Both these practices are ranked Tier 1 by Legal 500 UK. He has also worked in our Firm's Washington DC, New York and Sydney offices. Sunny also advises many clients on risk matters in India. He 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. The Legal 500 ranked Sunny as a “Leading Practitioner", and as "excellent", with a ‘calm’ and "very practical" approach. The India Business Law Journal also noted that Sunny is "excellent and has deep experience in India". He is a Visiting Professor at the College of Europe, the leading institute for post-graduate European studies, where he teaches a course on Corporate Compliance.

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Kerry Contini is a partner in the Firm's international trade practice in Washington, DC. She advises companies on export controls, sanctions, and related human rights and supply chain compliance issues. She has been with Baker McKenzie since she was a summer associate in 2005 and started as an associate in 2006. Kerry has been ranked in the Up and Coming categories for Export Controls & Trade Sanctions by Chambers Global (2022) and Chambers USA (2021), with clients highlighting that "her advice and solutions are business-focused" and that she is "very practical and easy to work with." Kerry has been recognized as a “standout” member of Baker McKenzie’s international trade team by Legal 500. 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 was recognized in the Who's Who Legal 2021 as a Global Leader in Trade & Customs - International Sanctions. Kerry has written on export controls and trade sanctions issues for a number of publications, including WorldECR, The Export Practitioner, and Ethisphere. She has presented on pandemic-related supply chain issues to the US International Trade Commission. Kerry has been quoted in a number of publications, including Global Investigations Review and Asian Legal Business. She is an editor of the Firm’s Global Supply Chain Compliance blog and is a regular contributor to that blog as well as the Firm’s Sanctions & Export Controls Update blog. Kerry is a co-chair of the Export Controls and Sanctions Section of the Association of Women in International Trade. Kerry is part of the diversity and inclusion leadership for the Washington DC office and is a member of the BakerWomen Steering Committee. She has maintained an active pro bono practice throughout her career at Baker McKenzie and is co-chair of the Washington DC office pro bono leadership team. Kerry has worked on a wide range of pro bono matters, primarily focusing on public international law, animal advocacy, and election protection. She is an active member of the Animal Law Committee of the Environment, Energy, and Natural Resources Community of the DC Bar.

Author

Gokce Serez is a lawyer at Esin Attorney Partnership, Istanbul office. She focuses her practice on corporate compliance, including corporate investigations, anti-bribery, anti-money laundering, anti- corruption, white-collar crimes, trade sanctions and export controls.

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