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.


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.