Fall of Afghanistan Leaves US Officials Scrambling Over Taliban Funding Streams
20 Aug 2021

The speed with which the Taliban seized control of much of Afghanistan last week took the U.S. military and intelligence apparatus by surprise, and handed the White House the difficult job of rapidly recalibrating their approach to the Islamist militia and its finances.

Global financial institutions already anticipate that the Treasury Department’s Office of Foreign Assets Control, or OFAC, will issue new guidance on how the Taliban’s expected role in leading the new Afghan government may impact any links they have, however remote, to the nation’s central bank, state-owned enterprises and private companies.

Amid fears of an impending humanitarian crisis in Afghanistan, OFAC may also need to clarify what basic exports of food, medicines, vaccines for the novel coronavirus and other aid U.S. firms and their banks should process first, while also implementing new sanctions or blacklisting additional Taliban members and entities under existing programs.

“For whatever components in each of those agencies that have responsibility for Afghanistan these are going to be very busy days trying to get their arms wrapped around what happened,” said Dennis Lormel, who co-founded and led the FBI’s Terrorist Financing and Operations Section following the Sept. 11 attacks.

The Taliban as a group is blacklisted, but only two of its leaders—deputy chief Sirajuddin Haqqani and military commander Mullah Mohammad Yaqoob—are subject to U.S. sanctions through executive orders 13224 and 13268, which ex-President George W. Bush signed in September 2001 and July 2002, respectively.

U.S. sanctions do not target any other high-ranking members of the Taliban or the group’s two most senior leaders: Haibatullah Akhundzada and Abdul Ghani Baradar.

The European Union, United Kingdom, Russia and Switzerland have blacklisted more individual Taliban members than the U.S. pursuant to U.N. Security Council Resolution 1373, a measure that the White House heavily supported after the attacks but never fully implemented, according to an analysis that Castellum, a provider of automated sanctions-screening products, shared with ACAMS

Peter Piatetsky, a former Treasury official who also served as an intelligence analyst with the U.S. Army, attributed the scarcity of American designations against the Taliban to resistance from the White House to blacklist the militia’s leaders during peace negotiations, as well as the view among some U.S. officials that the group’s reliance on informal financial channels would limit the efficacy of additional sanctions.

“In any case, even the existing sanctions mean that right now everything is de-facto blocked from the U.S. government’s perspective,” said Piatetsky, who co-founded Castellum two years ago. “The U.S. will slowly move in the direction of removing sanctions and issuing licenses, or impose more sanctions, depending on policy considerations and the Taliban’s behavior.”

By Valentina Pasquali, ACAMS, 18 August 2021

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