Markets Wired

WASHINGTON — Today, the United States is taking action against a network of three individuals associated with the expanded activities of the Islamic State of Iraq and Syria (ISIS) on the African continent. These individuals serve as key financiers and trusted operatives, enabling the activities of ISIS and its leaders across Central, Eastern, and Southern Africa. They also serve as critical links between far-flung ISIS operations, including ISIS affiliates in the Democratic Republic of the Congo (DRC), Mozambique, Somalia, and ISIS cells in South Africa, allowing ISIS leadership to leverage each affiliate’s capabilities to conduct terrorist attacks that undermine peace and security in the region. 

“Today’s action underscores the crucial work of the Counter ISIS Finance Group and the importance of effective information sharing among Coalition countries to target ISIS’s facilitation networks,” said Under Secretary of the Treasury for Terrorism and Financial Intelligence Brian E. Nelson. “While we have made considerable progress over the nearly ten years since the establishment of this working group, we must all remain vigilant because ISIS continues to develop new financial methods. The United States, in close coordination with our key partners, remains committed to disrupting the key nodes that enable disparate ISIS groups to work together and their ability to finance the group’s terrorist activities.”

This action is taken as part of the United States’ commitment to the mission of the Counter ISIS Finance Group (CIFG) that is holding its 20th meeting today to further international efforts to curb ISIS financing worldwide. The CIFG is a working group of the Global Coalition to Defeat ISIS, which includes over 80 countries and international organizations. 

Today’s designations are aimed at the threat ISIS poses to regional security and stability in Eastern, Central, and Southern Africa. Treasury has targeted ISIS’s efforts to expand operations and raise funds on the African continent with designations of South Africa-based ISIS operatives, financial facilitators, and their business networks in March 1, 2022 and November 7, 2022, and a designation of a key Somalia-based ISIS finance official on July 27, 2023. The individuals sanctioned today are being designated pursuant to Executive Order (E.O.) 13224, as amended, which targets terrorist groups and their supporters. 

ISIS FACILITATION NETWORK OPERATING ACROSS AFRICA

Abubakar Swalleh (Swalleh) is a South Africa- and Zambia-based ISIS operative. He is involved in the physical transfer of funds from South Africa to the DRC. Additionally, Swalleh facilitates the movement of ISIS-affiliated individuals from Uganda to South Africa, and vice versa. Mohamed Ali Nkalubo, a DRC-based ISIS commander previously designated by the Department of State on December 8, 2023, relies on Swalleh to move funds and recruit members for ISIS’s DRC affiliate. Swalleh moved to South Africa under Nkalubo’s direction, where he has been involved in robberies and kidnap for ransom. Zayd Gangat (Gangat) is a South Africa-based ISIS facilitator and trainer. ISIS leaders in South Africa have historically used robbery, extortion, and kidnap for ransom operations to generate funds for the group.

DRC-based Hamidah Nabagala (Nabagala) serves as an intermediary for ISIS financial flows in central Africa. Additionally, Nabagala has been accused of funding the October 2021 Kampala bombing, which killed one and injured at least three others. In 2021, Ugandan authorities arrested an ISIS operative that had received funding from Nabagala. She also sought to smuggle her three children out of Uganda to send them to ISIS-affiliate camps in the DRC.

Swalleh, Nabagala, and Gangat are being designated pursuant to E.O. 13224, as amended, for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, ISIS, a person whose property and interest in property are blocked pursuant to E.O. 13224.

SANCTIONS IMPLICATIONS

As a result of today’s action, all property and interests in property of the individuals named above, and of any entities that are owned, directly or indirectly, 50 percent or more by them, individually, or with other blocked persons, that are in the United States or in the possession or control of U.S. persons must be blocked and reported to OFAC. OFAC’s regulations generally prohibit all dealings by U.S. persons or within the United States (including transactions transiting the United States) that involve any property or interests in property of designated or blocked persons. U.S. persons must comply with OFAC regulations, including all U.S. citizens and permanent resident aliens regardless of where they are located, all persons within the United States, and all U.S.- incorporated entities and their foreign branches. Non-U.S. persons are also subject to certain OFAC prohibitions. For example, non-U.S. persons are prohibited from causing or conspiring to cause U.S. persons to wittingly or unwittingly violate U.S. sanctions, as well as engaging in conduct that evades U.S. sanctions. Violations of OFAC regulations may result in civil or criminal penalties. OFAC may impose civil penalties for sanctions violations based on strict liability, meaning that a person subject to U.S. jurisdiction may be held civilly liable even if such person did not know or have reason to know that it was engaging in a transaction that was prohibited under sanctions laws and regulations administered by OFAC. OFAC’s Economic Sanctions Enforcement Guidelines provide more information regarding OFAC’s enforcement of U.S. economic sanctions, including the factors that OFAC generally considers when determining an appropriate response to an apparent violation. For additional information on complying with U.S. sanctions and export control laws, please see Department of Commerce, Department of the Treasury, and Department of Justice Tri-Seal Compliance Note.

Furthermore, engaging in certain transactions with the individuals designated today entails risk of secondary sanctions pursuant to E.O. 13224, as amended. Pursuant to this authority, OFAC can prohibit or impose strict conditions on the opening or maintaining in the United States of a correspondent account or a payable-through account of a foreign financial institution that knowingly conducted or facilitated any significant transaction on behalf of a Specially Designated Global Terrorist.

The power and integrity of OFAC sanctions derive not only from OFAC’s ability to designate and add persons to the SDN List, but also from its willingness to remove persons from the SDN List consistent with the law. The ultimate goal of sanctions is not to punish, but to bring about a positive change in behavior. For information concerning the process for seeking removal from an OFAC list, including the SDN List, please refer to OFAC’s Frequently Asked Question 897 here. For detailed information on the process to submit a request for removal from an OFAC sanctions list, please click here.

View identifying information related to today’s action. 

###