Ongoing use of MSBs by ISIL
The US Department of the Treasury‘s Office of Foreign Assets Control sanctioned Afaq Dubai for the money services business’ involvement in moving funds for ISIL.
The Iraq-based MSB moved money for the Islamic State as recently as 2018. The MSB is believed to be part of ISIL’s financial facilitation network that includes other MSBs, hawalas, and financial facilitators.
Afaq Dubai was used by ISIL to provide funds to families of ISIL fighters and to “launder” funds for the terrorist organization, and was run by two ISIL financiers.
In May 2018, a Jordan-based financial facilitator deposited $3 million into three MSBs, including Afaq Dubai.
Analysis: The use of Iraq-based money services businesses is a well-established funds movement technique for ISIL. The group has also used MSBs to obscure their movement of funds by having MSB operators use false names or not record or report the transactions. The most valuable MSBs for any terrorist group are those that are controlled by individuals aligned with the group, as this allows them to move and obscure funds on behalf of the terrorist organization with little effort.