On November 9, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions pursuant to Executive Order 13224 against two business associates of a previously sanctioned al-Qa’ida financial facilitator and external operations plotter. According to OFAC, the two designated individuals in the recent action conducted business activities to assist the previously designated individual for facilitating the international movement of individuals and finances in furtherance of al-Qa’ida’s objectives. As a result of the sanctions, all property and interests in property belonging to the sanctioned persons subject to U.S. jurisdiction are blocked and must be reported to OFAC. Additionally, “any entities that are owned, directly or indirectly, 50 percent or more” by one or more blocked persons are also blocked. U.S. persons are also generally prohibited from engaging in any dealings involving the property or interests in property of blocked or designated persons. Persons that engage in certain transactions with the designated individuals or entities may themselves be exposed to secondary sanctions, OFAC warned, adding that foreign financial institutions that knowingly conduct or facilitate significant transactions to any of the sanctioned persons could also be subject to U.S. sanctions.