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Yesterday, the Treasury Department reported that OFAC designated two cybersecurity experts — Mu’min Al-Mawji Mahmud Salim and Sarah Jamal Muhammad Al-Sayyid — affiliated with the Islamic State of Iraq and Syria (ISIS) for providing ISIS leadership and supporters with cybersecurity training, enabling their use of virtual currency, and supporting the terrorist group’s recruitment. Additionally, OFAC designated Faruk Guzel, an ISIS financial facilitator involved in transferring funds to ISIS-affiliated individuals in Syria.

For identification information on the three designated individuals, see BankersOnline's January 30, 2024, OFAC Update.

On January 29, 2024, FinCEN announced it had issued a finding and notice of proposed rulemaking that identifies Al-Huda Bank, an Iraqi bank that serves as a conduit for terrorist financing, as a foreign financial institution of primary money laundering concern. Along with its finding, FinCEN proposed imposing a special measure that would sever the bank from the U.S. financial system by prohibiting domestic financial institutions and agencies from opening or maintaining a correspondent account for or on behalf of Al-Huda Bank.

UPDATED: Comments on the notice of proposed rulemaking will be accepted for 30 days (through March 1, 2024) following its January 31, 2024. publication at 89 FR 6074 in the Federal Register.

In a coordinated action, OFAC designated Hamad al-Moussawi, owner and chairman of Al-Huda Bank, for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, the IRGC-QF. His identifying information can be found in this BankersOnline OFAC Update.

FinCEN has published [89 FR 5995] in the January 30, 2024, Federal Register a Notice and Request for Comments on the proposed information collection associated with requests made to FinCEN, by certain persons, for beneficial ownership information, consistent with the requirements of the Beneficial Ownership Information Access and Safeguards final rule.

Included in the notice are FinCEN's estimates of the burden to state, local and tribal law enforcement agencies, and for financial institutions. An appendix to the Notice and Request for Comments summarizes the proposed data fields to be submitted by authorized recipients. Financial institutions would submit the reporting company name, TIN type, and TIN, and a check mark agreeing to a system-provided certification of compliance statement.

Comments will be accepted through April 1, 2024.

Note: This proposal does not in any way change the current rule in 31 C.F.R. § 1010.230 requiring financial institutions to obtain certification of beneficial ownership information from its customers. Amendments to that rule are not expected until at least the end of 2024.

The Treasury Department has reported the OFAC and the United Kingdom have taken joint action against a network of individuals that targeted Iranian dissidents and opposition activists for assassination at the direction of the Iranian regime. The network is led by Iranian narcotics trafficker Naji Ibrahim Sharifi-Zindashti (Zindashti) and operates at the behest of Iran’s Ministry of Intelligence and Security (MOIS). Treasury reports that Zindashti’s network has carried out numerous acts of transnational repression including assassinations and kidnappings across multiple jurisdictions in an attempt to silence the Iranian regime’s perceived critics. The network has also plotted operations in the United States.

For identification information on the targeted individuals, see this BankersOnline's OFAC Update.

The Treasury Department reported yesterday that OFAC has imposed sanctions on key officials of the forces of Ansarallah, commonly known as the Houthis, for their support of acts of terrorism targeting commercial shipping. Yesterday’s action targets four individuals who have supported the Houthis’ recent attacks against commercial vessels in the Red Sea and Gulf of Aden, including holding civilian crews hostage. Concurrent with OFAC’s designations, the United Kingdom also imposed sanctions on these key figures of Houthi forces.

For the names and identification information of the four individuals, see yesterday's BankersOnline OFAC Update.

Federal Reserve Financial Services has announced its launch of FedDetect Anomaly Notification for FedACH Services, a new risk management service that helps financial institutions identify anomalous activity and supplement their fraud detection and alerting tools. This new addition to FedACH Risk Management Services allows financial institutions to receive notifications via secure email when anomalous FedACH activity is detected.

The new service can help financial institutions catch potential fraud attempts with account verification through micro-entry return and forward-entry monitoring. It can also help originating financial institutions adhere to Nacha rules around notifications of change and avoid future rule violations.

This morning, FinCEN published [89 FR 4820] a final rule to reflect inflation adjustments to its civil monetary penalties as mandated by the Federal Civil Penalties Inflation Adjustment Act of 1990, as amended. This rule adjusts certain maximum civil monetary penalties within the jurisdiction of FinCEN to the amounts required by that Act.

The rule amends 31 CFR 1010.821 and is effective today.

On Tuesday, OFAC, in coordination with Australia and the United Kingdom, designated Alexander Ermakov, a cyber actor who played a pivotal in the 2022 ransomware attack against Medibank Private Limited, an Australian healthcare insurer.

Australia sanctioned Ermakov on Monday for utilizing ransomware to attack the Medibank network and for the exfiltration of sensitive data of 9.7 million users of Medibank services. Tuesday, the United States and the United Kingdom, in solidarity with Australia, took action against Ermakov because of the similar risk he presents to the United States and the UK.

For identification information on Ermakov, see BankersOnline's January 23, 2024, OFAC Update.

The Department of the Treasury on Monday announced that OFAC had designated Iraqi airline Fly Baghdad and its CEO for providing assistance to the Islamic Revolutionary Guard Corps–Qods Force (IRGC-QF) and its proxy groups in Iraq, Syria, and Lebanon. OFAC also designated three leaders and supporters of one of the IRGC-QF’s main Iran-aligned militias in Iraq, Kata’ib Hizballah (KH), as well as a business that moves and launders funds for KH.

Treasury also announced that OFAC has imposed a fifth round of sanctions on Hamas since the October 7 terrorist attack on Israel. Monday’s action targets networks of Hamas-affiliated financial exchanges in Gaza, their owners, and associates, and particularly financial facilitators that have played key roles in funds transfers, including cryptocurrency transfers, from the Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF) to Hamas and Palestinian Islamic Jihad (PIJ) in Gaza. Concurrent with OFAC’s designations, the United Kingdom and Australia are also placing sanctions on key Hamas officials and facilitators.

For the names and identification information of individuals, entities, and aircraft targeted in these OFAC actions, see the January 22, 2024, BankersOnline OFAC Update.

OFAC has released the first video in its "OFAC Basics" video series. The OFAC Basics: Sanctions List Search YouTube video provides viewers with a brief tutorial on how to use OFAC’s Sanctions List Search Tool and recommended steps for assessing a potential match to one of OFAC’s published sanctions lists.

The “OFAC Basics” series serves as a companion series to the “Introduction to OFAC” series, also available on YouTube.