Designation Date: 22 June 2026
Issuing Authority: Office of Foreign Assets Control (OFAC), U.S. Department of the Treasury
Legal Basis: Executive Order 13224, as amended (counterterrorism sanctions authority)
Overview
On 22 June 2026, OFAC designated three individuals and six entities across Europe, the Middle East, and West Africa for facilitating financial transactions on behalf of the Islamic State of Iraq and Syria (ISIS).
The action targets the facilitators who let ISIS move funds between its regional affiliates. One of the designated networks operated through crypto: Bitcoin Xchange, a Syria-based money service business (MSB) established in late 2020, moved funds for ISIS associates originating in Norway, Belgium, the Netherlands, South Africa, and the United States.
Nominis assesses the connected network to be larger than the public action captures. Our analysis traces more than $100 million moving through the wider set of facilitators and exchange businesses tied to these actors, much of it well before any of the names reached the SDN List.
“Meaningful counterterrorism prevention cannot stop at identifying one facilitator or freezing a few accounts. Terrorist financing networks are built to adapt, reroute, and survive partial disruption - we see this every day at NOMINIS. To truly degrade their operational capability, the entire network, including its intermediaries, companies, wallets, money-service businesses, and cross-border facilitators, must be traced, exposed, and sanctioned.
Only a network-wide response can turn financial intelligence into lasting counterterror impact.”
About ISIS and its Financial Facilitators
ISIS was designated by the U.S. Department of State as a Specially Designated Global Terrorist under E.O. 13224 on 15 October 2004, under its former name Al-Qa'ida in Iraq, and as a Foreign Terrorist Organization under section 219 of the Immigration and Nationality Act on 17 December 2004.
Sustained counterterrorism pressure has pushed ISIS toward a far more decentralised structure, relying on autonomous cells and affiliates worldwide. Financial facilitators provide the connectivity between those nodes and ISIS's General Directorate of Provinces, which directs operational guidance and funding to regional offices. This pattern is set out in Treasury's 2026 National Terrorist Financing Risk Assessment and FinCEN's April 2025 Advisory on the Financing of ISIS and its Global Affiliates.
Observed financial behaviour across these networks includes:
- Movement of funds through money service businesses and informal hawala networks
- Use of crypto exchanges to bridge value across borders and jurisdictions
- Layering through intermediaries to obscure the origin and destination of funds
- Cross-border transfers routed outside regulated financial institutions
Crypto here functions as one method within a broader facilitation framework, rather than as a standalone system.
Designated Individuals
- Miloud Abderrahmane (France) - a French national who conducted transactions with known ISIS affiliates, including individuals based in Syria.
- Abdelhakim Boukich (Syria) - a former Dutch national who controls and directs Bitcoin Xchange, the Syria-based MSB named in this action.
- Mukhtar Adamu Muhammad (Nigeria) - an ISIS in West Africa (ISIS-WA) facilitator who has conducted money transfers on behalf of ISIS-WA.
Related: Mohamad Alhmidan, previously designated by OFAC in March 2016, controls the two Türkiye-based businesses named below. He is referenced in this action but was not newly designated.
Designated Entities
- Bitcoin Xchange - Syria-based money service business; controlled by Abdelhakim Boukich.
- Spider Gayrimenkul Ve Genel Ticaret Limited Sirketi ("Spider") - Türkiye-based MSB that originated as a Syrian hawala used to move funds out of ISIS-controlled territory; controlled by Mohamad Alhmidan.
- Alkaram Danismanlik Gayrimenkul Ic Ve Dis Genel Ticaret Limited Sirketi ("Alkaram") - Türkiye-based MSB that does business as, and operates on behalf of, Spider.
- Nine to Nine Exchange Bureau de Change Limited ("Nine Exchange") - Nigeria-based MSB owned, controlled, or directed by Mukhtar Adamu Muhammad.
- Manhattan Bureau de Change Limited ("Manhattan Bureau") - Nigeria-based MSB owned, controlled, or directed by Mukhtar Adamu Muhammad.
- Generation Currency Bureau de Change Limited ("Generation Currency") - Nigeria-based MSB owned, controlled, or directed by Mukhtar Adamu Muhammad.
All parties were designated under E.O. 13224, as amended, for materially assisting, sponsoring, or providing financial, material, or technological support to ISIS or ISIS-WA, or for being owned or controlled by a designated facilitator.
Recognising the full network
As mentioned, NOMINIS believes that the network currently targeted in this OFAC designated is actually larger than the public action captures.
The following screenshots of the NOMINIS platform’s risk screening feature demonstrate the analysis of wallets that also operate within the targeted terror network, but have remained undesignated by OFAC at the time of writing.
The movement of funds in and out of these wallets demonstrate the vast amount of dollars used for terror financing that remain unsanctioned and free for movement to other ISIS-controlled wallets.
On the topic, Founder and CEO of NOMINIS, Snir Levi, notes, “Meaningful counterterrorism prevention cannot stop at identifying one facilitator or freezing a few accounts. Terrorist financing networks are built to adapt, reroute, and survive partial disruption - we see this every day at NOMINIS.
To truly degrade their operational capability, the entire network, including its intermediaries, companies, wallets, money-service businesses, and cross-border facilitators, must be traced, exposed, and sanctioned.’
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Compliance Obligations
All property and interests in property of the officially designated persons that are in the United States, or in the possession or control of U.S. persons, are blocked and must be reported to OFAC. Any entity owned 50 percent or more, directly or indirectly, by one or more blocked persons is also blocked.
Obligations include:
- Blocking any property or interests in property linked to designated parties
- Reporting blocked holdings to OFAC
- Maintaining ongoing sanctions screening and transaction monitoring across counterparties
Unless authorised or exempt, OFAC's regulations generally prohibit all transactions by U.S. persons, or within or transiting the United States, involving blocked persons' property. Civil penalties may apply on a strict liability basis. Non-U.S. parties may face secondary sanctions exposure, including restrictions on correspondent or payable-through accounts, where they knowingly facilitate significant transactions for designated actors.
The Treasury was explicit that exposure does not depend on intent. Facilitators expose firms to the full breadth of its authorities whether support is provided knowingly or through compliance system failures. The same action that names a willing facilitator can reach the business that did not recognise the transaction for what it was.
Clients of NOMINIS will also be warned not to interact with other wallets that have been determined as involved in the terror network.
Official Designation Document
OFAC Recent Actions – 22 June 2026: https://ofac.treasury.gov/recent-actions/20260622 Treasury Press Release: https://home.treasury.gov/news/press-releases/sb0537
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