On June 6, 2016, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) released its 24th annual Terrorist Assets Report (TAR), an update to Congress detailing the amounts of assets in relation to international terrorist organizations or state sponsors of terrorism that have been frozen up until December 31, 2015.

https://www.treasury.gov/resource-center/sanctions/Programs/Documents/tar2015.pdf

The TAR, which is prepared based on information from the Department of the Treasury and other governmental/non-government agencies, can also serve as a useful guide for compliance professionals in that it provides information regarding the nature and type of US terrorist sanctions regimes currently in place.

According to OFAC, the blocked asset amounts contained in the TAR “represent amounts frozen under US sanctions programs that block all property and interests in property in the US or in the possession or control of a US person (or, in the case of Cuba, a person subject to U.S. jurisdiction) of designated or blocked parties”.

Assets relating to International Terrorist Organizations

The report indicates that around $37.6 million worth of assets were blocked by OFAC and other US agencies in relation to international terrorist organizations, which have been designated by Executive Order (EO) or Act of Congress.

These include

1. Specially Designated Global Terrorists (SDGTs) (EO 13224),
2. Specially Designated Terrorists (SDTs) (EOs 12947 and 13099), and
3. Foreign Terrorist Organizations (FTOs) under the Anti-Terrorism Act of 1996.

The above figure represents an increase from $21.8 million worth of blocked assets as of 2014.

The biggest organization driving the increase in frozen assets were blocked accounts and wire transfers in which Iran’s Islamic Revolutionary Guard Corps (IRGC) had an interest, for a total of $14.1 million.

This is the first year in which the IRGC has had an interest added to the totals in the TAR. Al-Qaida was second with $13 million in blocked assets, and the Lebanese militant group, Hizballah, trailed slightly behind with $8 million in blocked assets.

Also added for the first time in 2015, was the Islamic State of Iraq and the Levant (ISIL), which had $131,392 in total blocked accounts and wire transfers.

According to OFAC, “US persons are prohibited from conducting unauthorized transactions or having other dealings with or providing services to [these] designated individuals or entities”.

Assets relating to Designated State Sponsors of Terrorism

The report goes on to indicate that approximately $2.3 billion in assets have been frozen under US sanctions targeting four designated state sponsors of terrorism – Cuba, Iran, Sudan, and Syria. Note, this amount includes Cuban assets as of 31 December 2015, though Cuba’s designation as a state sponsor of terrorism was rescinded as of May 2015. This is because Cuba was still designated as a state sponsor of terrorism for part of 2015, and because, despite the recent easing of sanctions against Cuba, certain assets remain blocked.

The bulk of frozen assets belong to Iran at a total of $1.98 billion, with Cuba coming in second at $243.2 million in frozen assets. The biggest rise in frozen assets, however, belongs to Syria with an increase from $3 million in 2015 to $25.9 million blocked funds in 2015.

Real Property owned by State Sponsors of Terrorism

The above figures exclude real and tangible property owned by state sponsored terrorists, as OFAC does not conduct valuations of tangible property or appraisals of real property. It is important to note, however, that all of the aforementioned state sponsors of terrorism own diplomatic and consular real property in the US, namely New York, New Jersey, Washington D.C., Virginia, Illinois, Maryland, Texas, and California.

In addition, there are three organizations that currently own blocked real and tangible property inside the US:

1. the Benevolence International Foundation owns real estate in the greater Chicago area;
2. the Islamic American Relief Agency owns an interest in real property in Missouri; and
3. the Al Haramain Islamic Foundation owns real property in Missouri.

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