More evidence revealed about ISIL using Turkey as conduit to move funds


Another piece of evidence showing how the Islamic State in Iraq and the Levant (ISIL) has been operating in the permissive environment in Turkey of President Recep Tayyip Erdoğan was unearthed by a recent designation of the US Department of the Treasury’s Office of Foreign Assets Control (OFAC).

According to a press release issued by OFAC on April 16, 2019 several individuals and a business that are operating the Rawi Network, a key ISIL financial facilitation group based out of Iraq, have been involved in moving funds for ISIL through contacts in Turkey. Among the seven individuals designated by OFAC is Mushtaq Talib Zughayr al-Rawi, the leader of the Rawi Network who has business contacts in Turkey as well as in Iraq, Syria, Sudan and the Gulf. He was designated for assisting in, sponsoring, or providing financial, material or technological support for, or financial or other services to, or in support of, ISIL.

Mushtaq operates the Rawi Network with the assistance of various family members, including his son, Muhannad Mushtaq Talib Zughayr al-Rawi, his brothers, Umar Talib Zughayr al-Rawi and Walid Talib Zughayr al-Rawi, and others, including Abd-al-Rahman al-Rawi. As of November 2017, Mushtaq oversaw money transfers for ISIL using a hawala network — a system or agency for transferring money traditionally used in the Muslim world — throughout Iraq and Turkey. As of early May 2018, Mushtaq and a family member operated an ISIL hawala from the Al­-Ard Al-Jadidah Money Exchange Company in Turkey’s northwestern Samsun province. They also used the Iraqi government’s pension system to launder funds for ISIL, and Mushtaq owns at least three QiCard businesses in Iraq’s al-Qa’im and Ramadi districts as well as in Turkey’s Samsun province.


As of October 2018, Mushtaq moved to Belgium but operated a finance network that allegedly used various commercial establishments in Iraq, hawalas in Iraq and Turkey, unidentified individuals in the Gulf and an unidentified West Bank-based charity to generate, launder and move cash into Iraq and Syria on behalf of ISIL.

The evidence was obtained in November 2018 when US-led anti-ISIL coalition advisors their local partner raided Mushtaq’s compound and seized financial records that revealed that he had business dealings with ISIL.

The Rawi Network was a useful business enterprise in helping Saddam Hussein evade sanctions in the 1990s, employing sophisticated money transfer methods including exchange houses and hawala systems. Mushtaq served as a captain in Saddam Hussein’s Republican Guards and was detained in 2007 in Iraq’s al-Qa’im as a suspected insurgent financier. In recent years his network helped ISIL move funds worldwide by employing common money laundering techniques as well. For example, on a regular basis, the deputy commander for ISIL’s Department of Oil transferred between $300,000 to $400,000 to Umar Talib Zughayr al-Rawi, also designated by OFAC, to buy and sell gold and eventually convert the gold proceeds back into cash for ISIL, the US Treasury statement said.

ISIL members in Syria’s Idlib Province were paid by a finance administrator who sent the payroll to firms owned by Mushtaq and another individual in Dayr az Zawr Province, Syria.

Umar Talib Zughayr al-Rawi and Abd al Rahman Ali Husayn al-Ahmad al-Rawi were selected to manage the financial affairs for ISIL’s so-called province of al-Furat after the death in a coalition airstrike in 2017 of Fawaz Muhammad Jubayr al-Rawi, a designated Syrian terrorist and financial facilitator who moved millions of dollars for ISIL’s attack and logistics networks. Umar, Abd al-Rahman and Mushtaq Talib Zughayr al-Rawi were all business partners with Fawaz. The financial records associated with Mushtaq revealed a history of direct money transfers to support ISIL provincial leaders through the Al-Ard Al-Jadidah Money Exchange Company.



Umar and Abd-al-Rahman also transferred funds to Iraq to purchase vehicles for ISIL fighters and exchanged cash for ISIL coinage. As of early September 2017 Umar was an ISIL financial facilitation leader who received both money and gold from ISIL and transferred the money (or the equivalent value of the gold) for ISIL. He transferred money throughout Iraq and conducted transactions to and from Turkey.

He operated businesses in al-Qa’im, Ramadi, Hit and Baghdad in Iraq; Albu Kamal, Syria; and Turkey. In al-Qa’im, Umar operated a currency exchange, handling large amounts of money, and transferred money for ISIL. In Ramadi, Iraq, Umar was the co-owner of a currency exchange that ISIL used to make a significant number of money transfers within Anbar Province. Umar had other hawalah and money transfer offices used by ISIL members that were operated in partnership with other Rawi Network members.

Walid Talib Zughayr al-Rawi was designated for assisting in, sponsoring or providing financial, material or technological support for, or financial or other services to, or in support of, Mushtaq.

Mushtaq moved money for ISIL out of al-Qa’im, Iraq, and Samsun, Turkey. However, Mushtaq’s brother, Walid, was purportedly the brains behind the finance operation. On October 9, 2018 the Iraq Counterterrorism Service (CTS) conducted a warrant-based arrest of Walid to disrupt the ISIL financial network.

Mushtaq and Walid started in the currency exchange business when sanctions were imposed on Iraq’s oil exports in the 1990s. Walid has held money from numerous relatives and associates. These individuals were investing in Walid’s various enterprises, to include Walid’s numerous government of Iraq contracts. These individuals were given a certain rate of return or interest on their investment. Mushtaq invested $900,000 with Walid. Moreover, Mushtaq had Walid transfer money to two gold shops in the Gulf. Walid transferred these funds approximately three times per month, totaling $100,000, and started sending money to these gold shops for approximately one year prior to Walid’s detention on October 9, 2018.

Walid informed an unidentified individual of nearly $3.9 million in financial transactions for funds sent to entities in Iraq and the Gulf from early December 2017 through early July 2018. The unidentified individual noted that at least $700,000 was deposited for Mushtaq as of February 2018.

Walid handled transfers to and from a Gulf-based exchange on behalf of Umar as well as Umar’s investments in unspecified businesses. Umar has $500,000 invested with Walid.

Muhannad Mushtaq Talib Zughayr al-Rawi was designated for assisting in, sponsoring, or providing financial, material or technological support for, or financial or other services to, or in support of, Mushtaq.

Mushtaq’s financial activity consisted of a cycle of monetary transactions that included his son Muhannad and three other financial facilitators. When Mushtaq conducted transactions with a certain exchange company, he moved money from Turkey to Muhannad. Muhannad then moved Mushtaq’s money to the exchange, which then transferred Mushtaq’s money to a gold exchange in the Gulf, earmarked for a specific gold seller.

As of September 2017 Muhannad moved from Baghdad to Samsun, Turkey, to work with Mushtaq.

Abd-al-Rahman ‘Ali Husayn al-Ahmad al-Rawi (Abd-al-Rahman) was designated for assisting in, sponsoring, or providing financial, material, or technological support for, or financial or other services to, or in support of, ISIL.

As of September 2018 both Istanbul, Turkey-based Syrian national Abd-al-­Rahman and an Idlib Province, Syria-based Syrian hawaladar had allegedly established a secret partnership with two Syria-based Iraqi brothers to facilitate financial transfers into Syria on behalf of ISIL via hawala networks. Both the Syria-based hawaladar and Abd-al-Rahman conducted a large volume of legitimate business through their companies. However, they also moved money for ISIL in secret.

As of late 2017 a Turkey-based merchant, who was one of the primary ISIL financial facilitators in Syria, was maintaining a business partnership with ISIL financier Abd-al-Rahman. Abd-al-Rahman was one of a few individuals who provided ISIL significant financial facilitation into and out of Syria. Abd-al-Rahman instructed ISIL fighters seeking to move large sums of money out of Syria to deposit the money with an office in Syria. Furthermore, when individuals wanted to send money from Turkey to ISIL members in Syria, the instructions involved Abd-al ­Rahman.

Abd-al-Rahman had a hard-currency liquidity of several million dollars in Syria. He served as ISIL’s general financial manager, and prior to his relocation to Turkey, he traveled around Syria on behalf of the group. As of late October 2017, Abd-al-Rahman was allegedly continuing to conduct financial transactions on behalf of ISIL. As of mid-November 2017 Abd-al­-Rahman was maintaining a close and continuing partnership with an unidentified merchant, moving large sums of money on behalf of ISIL. Abd-al-Rahman was so influential within ISIL that he had the ability to change a death sentence into a short prison term.

As of late 2017 Abd-al-Rahman and his business partner and cousin, Umar, also designated, had been selected to manage financial affairs for ISIL’s Wilayah al-Furat following the death of Fawaz al-Rawi. As of late 2017, both Abd-al-Rahman and Umar, who had been partners in a currency exchange company in al-Qa’im, Anbar Province, Iraq, with Fawaz al-Rawi, had formally accepted their appointments. Abd-al-Rahman was responsible for external ISIL money transfer originating from and destined for foreign countries.

Abd-al-Rahman entered into a secret business relationship with a Turkey-based individual who specialized in conducting large-sum hawala transfers from the Gulf, including funds intended for ISIL. This individual facilitated a $250,000 hawala transfer to Abd-al-Rahman.

Muhammad Abd-al-Qadir Mutni Assaf al-Rawi was designated for assisting in, sponsoring, or providing financial, material, or technological support for, or financial or other services to, or in support of, ISIL.

Muhammad was used to transfer Mushtaq’s money to two gold shops in the Gulf, and Muhammad transferred approximately $100,000 per month for these transactions.

Members of the Rawi Network registered several businesses with the government of Iraq in order to acquire QiCard machines, a dedicated system of electronic payment machines used by the the government to disburse payments to government employees and retirees. They used these machines to launder funds for ISIL inside and outside of Iraq. The Rawi Network used funds provided by ISIL to purchase and license at least five QiCard machines.

In February 2017 ISIL financial facilitator in Iraq, Walid al-Rawi, also designated, used Muhammad to conduct a financial transfer of $40,000 to a Turkey-based ISIL financial facilitator.

As of 2016 ISIL members were using Muhammad and his business to transfer money to various countries in the Middle East and Europe.

The Al-Ard Al-Jadidah Money Exchange Company was designated for assisting in, sponsoring, or providing financial, material, or technological support for, or financial or other services to, or in support of, ISIL.

As of late 2018 Al-Ard al-Jadidah was serving as a money exchange used by ISIL members in Iraq and was wittingly transferring money for ISIL and delivering money to all the provinces of lraq. In 2018 an ISIL member collected a hawala transfer of over $1 million on behalf of ISIL at a branch of Al-Ard al-Jadidah in Iraq. Separately, in 2018, an ISIL member collected a transfer of hundreds of thousands of dollars from Al-Ard al-Jadidah in Ramadi, Anbar Province, Iraq. These funds were designated as financial support intended for distribution to ISIL family members.

Additionally, in late October 2018 Mushtaq facilitated money transfers between Al-Ard al-Jadidah in Samsun and hawalas in Iraq.

Halima Adan Ali was designated for assisting in, sponsoring, or providing financial, material, or technological support for, or financial or other services to, or in support of, ISIL.

Halima played an integral role in an ISIL financial facilitation network spanning Europe, the Middle East, the Americas and Eastern Africa. She worked with the Treasury-designated Waleed Ahmaed Zein to conduct transactions at the behest of Waleed’s Syrian-based family member in support of ISIL fighters. Between 2017 and early 2018 Halima received large sums of money from around the world, mostly through hawala systems, that she would forward to ISIL fighters in Syria, Libya and central Africa. She was also used as a conduit to pass instructions, money and accounts to Waleed. Their intricate network moved over $150,000 on behalf of ISIL.

Halima, who before becoming associated with ISIL served as an extremist recruiter and facilitator for al-Shabaab, planned to travel from East Africa to Syria and other ISIL-supported areas in August 2014 but was left behind when she was arrested for activities in support of al-Shabab. Waleed’s Syria-based family member worked through proxy channels to provide funds to secure Halima’s release from prison on bond, after which she began to work closely with him in support of ISIL. Halima was arrested again by Kenyan security services in July 2018.


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