On 15 July 2020, the U.S. and Gulf Cooperation Council (GCC)-led Terrorist Financing Targeting Center (TFTC) designated six targets affiliated with the Islamic State of Iraq and Syria (ISIS), including an entity allegedly posing as a charity (and its director) based in Afghanistan that allegedly provided support to ISIS’ branch in that country, ISIS-Khorasan (ISIS-K).

The entities that were designated are:

  • Al Haram Exchange
  • Tawasul Company
  • Al-Khalidi Exchange
  • Nejaat Social Welfare Organization

Five of these targets (which includes one individual) were previously designated as Specially Designated Nationals (“SDNs”) by the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) in September 2019 pursuant to the anti-terrorism authorities in Executive Order (EO) 13224, as amended by EO 13886. All property and property interests of the SDNs in the U.S. or in the possession or control of U.S. persons must be blocked and reported to OFAC, and all transactions involving U.S. Persons or with a U.S. nexus are prohibited. Also, OFAC has the ability to impose sanctions on non-U.S. persons who provide support to such SDNs, which could include prohibiting or restricting access to the U.S. financial system.  

With regards to the recent TFTC designation, the UAE implements all sanctions designated by the TFTC by issuing the Terrorism Lists pursuant to either the UAE AML Law and/or the UAE CTF Law (mentioned below), or UAE Federal Cabinet Decision No. 20 of 2019 on the Regulation of Terrorism Lists and Implementation of Security Council Resolutions Related to the Prevention and Suppression of Terrorism and Cessation of Proliferation of Weapons and its Financing, and the Relevant Decisions (the “UAE Sanctions Law”). The other GCC Member States have legislation in place to replicate the same actions.

To read the rest of this article by Borys Dackiw, Samir Safar-Aly and Kerry B. Contini, please go to our Sanctions Blog page here.


Ms. Contini focuses her practice on export controls, trade sanctions, and anti-boycott laws. This includes advising US and multinational companies on trade compliance programs, risk assessments, licensing, review of proposed transactions and enforcement matters. Ms. Contini works regularly with companies across a wide range of industries, including the pharmaceutical/medical device, oil and gas, and nuclear sectors.


Borys has been a partner of Baker McKenzie since 1995. In 2008 Borys was appointed managing partner of the Gulf offices (including Abu Dhabi, Doha, Riyadh and Bahrain), coordinating the opening of the Abu Dhabi and Doha offices and the merger in the UAE with Habib Al Mulla in July 2013.