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3/19/2020

Treasury Designates ISIS Financial, Procurement, and Recruitment Networks in the Middle East and South Asia | U.S. Department of the…

Treasury Designates ISIS Financial, Procurement, and
Recruitment Networks in the Middle East and South Asia
November 18, 2019

Washington – Today, the U.S. Department of the Treasury’s O ice of Foreign Assets Control
(OFAC) designated two Turkey-based Islamic State of Iraq and Syria (ISIS) procurement agents
and four ISIS-linked companies operating in Syria, Turkey, and across the Gulf and Europe for
providing critical financial and logistical support to ISIS. Additionally, Treasury is acting against
an Afghanistan-based organization, Nejaat Social Welfare Organization, for using false charitable
pretenses as a cover to facilitate the transfer of funds and support the activities of the terrorist
group’s branch in Afghanistan, ISIS – Khorasan (ISIS-K). Treasury also took action against two
senior o icials a iliated with this organization.
“Following the highly successful operation against al-Baghdadi, the Trump Administration is
resolved to completely destroy ISIS’s remaining network of terror cells,” said Treasury Secretary
Steven T. Mnuchin. “The Treasury Department contributes to this e ort in several ways,
including by degrading ISIS’s ability to recruit and arm fighters globally by stamping out its
financial footholds.”
These targets have been designated pursuant to Executive Order (E.O.) 13224, as amended,
which targets terrorists and those who have materially assisted, sponsored, or provided
financial, material, or technological support for, or goods or services to or in support terrorists.
This action further coincides with the twel h meeting of the Counter ISIS Finance Group (CIFG),
which includes 56 countries and international organizations. As a working group of the Global
Coalition to Defeat ISIS, the CIFG plays a fundamental role in coordinating e orts to isolate ISIS
from the international financial system and eliminate its sources of revenue. The CIFG is cochaired by Treasury’s Assistant Secretary for Terrorist Financing, Marshall Billingslea.
The United States plans to work with our United Nations and CIFG partners to nominate these
targets to the United Nations ISIL (Da’esh) and al-Qa’ida Sanctions List and will continue to work
with our United States and CIFG partners to further target ISIS and dismantle their financial
networks. The Treasury Department remains committed to safeguarding charities from terrorist

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Treasury Designates ISIS Financial, Procurement, and Recruitment Networks in the Middle East and South Asia | U.S. Department of the…

abuse and will continue to identify and disrupt the operations of sham organizations that
undermine the integrity of the charitable sector.
Sahloul Money Exchange Company (Sahloul)
Sahloul has materially assisted, sponsored, or provided financial, material, or technological
support for, or goods or services to or in support of, ISIS.
In late 2017, Sahloul held deposits from ISIS-linked individuals seeking transport out of Syria to
Turkey.
In late 2016, Sahloul facilitated the transfer of foreign donations to ISIS’s then-headquarters in
Mosul, Iraq.
Additionally, Sahloul transferred thousands of dollars to ISIS operatives in Turkey in 2016.
Al-Sultan Money Transfer Company (Al-Sultan)
Al-Sultan has materially assisted, sponsored, or provided financial, material, or technological
support for, or goods or services to or in support of, ISIS.
Al-Sultan has been involved in transferring ISIS money.
In mid-2019, an ISIS associate identified Al-Sultan as an exchange that could be used avoid
scrutiny when transferring funds.
Tawasul Company (Tawasul)
Tawasul has materially assisted, sponsored, or provided financial, material, or technological
support for, or goods or services to or in support of, ISIS.
As of mid-2018, a Syria-based ISIS financial facilitator had transferred funds via Tawasul’s o ice
in Harim, Syria.
As of 2018, ISIS allegedly had used Tawasul, as well as multiple other companies in Syria and
Western Europe, to transfer money among ISIS fighters.
Ismail Bayaltun
Ismail Bayaltun has materially assisted, sponsored, or provided financial, material, or
technological support for, or goods or services to or in support of, ISIS.
Turkey-based Ismail Bayaltun and his brother Ahmet Bayaltun—through a company they owned
in Sanliurfa, Turkey—have provided support to ISIS fighters.

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As of late 2018, Ismail Bayaltun and his siblings provided material support to ISIS through ACL
Ithalat Ihracat. The company supplied ISIS with equipment in 2015 and 2017.
Ahmet Bayaltun
Ahmet Bayaltun has materially assisted, sponsored, or provided financial, material, or
technological support for, or goods or services to or in support of, ISIS.
As of early 2017, Turkey-based Ahmet Bayaltun was identified as an ISIS procurement agent.
ACL Ithalat Ihracat
ACL Ithalat Ihracat is owned, controlled, or directed by Ismail Bayaltun, a person whose
property and interests in property are blocked pursuant to E.O. 13224, as amended.
As of 2018, Ismail Bayaltun was the Chairman of the Board of Directors of ACL Ithalat Ihracat and
operated ACL Ithalat Ihracat with his siblings.
Nejaat Social Welfare Organization (Nejaat)
The Nejaat Social Welfare Organization has materially assisted, sponsored, or provided
financial, material, or technological support for, or goods or services to or in support of, ISIS-K.
Nejaat was used as a cover company to facilitate the transfer of funds and support the activities
of ISIS-K.
In late 2016, Afghan leaders of ISIS-K held planning meetings under the cover of a Salafi
solidarity meeting sponsored by Nejaat. Executive members of Nejaat and prominent Salafi
leaders in Afghanistan led the meeting, some of whom were financial supporters of Nejaat.
Rohullah Wakil, also designated today, was one of the executive members of Nejaat who co-led
the meeting.
In mid-2016, an ISIS-K facilitator managed a non-governmental organization called Nejaat. An
ISIS-K recruiter worked at Nejaat and recruited ISIS-K fighters in Kabul and arranged for their
travel to Nangarhar Province.
Nejaat collected donations on behalf of ISIS-K from individuals in Qatar, the United Arab
Emirates, Iraq, and other Middle Eastern countries. Money was then transferred from the Gulf to
Asia—via the banking system—where an ISIS-K coordinator would collect the transferred funds.
Nejaat’s o ices in Kabul and Jalalabad distributed the funds to ISIS-K commanders.
Sayed Habib Ahmad Khan

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Sayed Habib Ahmad Khan is a leader or o icial of the Nejaat Social Welfare Organization, an
entity whose property and interests in property are blocked pursuant to E.O. 13224, as
amended.
As of 2019, Sayed Habib Ahmad Khan was identified as the director of Nejaat. He is located in
Kuwait.
Additionally, Sayed Habib Ahmad Khan has been identified as an ISIS-K facilitator.
Rohullah Wakil
Rohullah Wakil has materially assisted, sponsored, or provided financial, material, or
technological support for, or goods or services to or in support of, ISIS-K.
Rohullah Wakil is an executive member of Nejaat who co-led a 2016 Nejaat Salafi solidary
meeting which served as a cover for ISIS-K planning.
SANCTIONS IMPLICATIONS
As a result of today’s action, all property and interests in property of these targets 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 blocked or designated persons. In addition, persons that engage in certain
transactions with the individual designated today may themselves be exposed to sanctions or
subject to an enforcement action.
Furthermore, pursuant to E.O. 13224, as amended by E.O. 13886, all Specially Designated Global
Terrorists (“SDGTs”) are now subject to secondary sanctions. 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 by a foreign financial institution that knowingly facilitates a significant
transaction for any SDGT, or a person acting on behalf of or at the direction of, or owned or
controlled by, a SDGT.
View identifying information related to today’s action here.

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