In the past week, both the US Treasury Department’s Office of Foreign Assets Control (OFAC) and the Financial Crimes Enforcement Network (FinCEN) have taken actions related to Hamas in response to recent attacks on Israel.
New OFAC Sanctions
On October 18, 2023, OFAC added several individuals and one entity linked to Hamas to its Specially Designated Nationals and Blocked Persons List (SDN). These designations include ten key Hamas members, operatives, and financial facilitators in Gaza, Sudan, Turkey, Algeria, and Qatar. Among these designations is a Gaza-based business providing money transfer and virtual currency exchange services, including Bitcoin.
Hamas, along with Palestinian Islamic Jihad (PIJ) and the Popular Front for the Liberation of Palestine (PFLP), has been designated as a Foreign Terrorist Organization by the US State Department since October 1997 and as Specially Designated Global Terrorists (SDGTs) since October 2001.
US individuals are generally prohibited from engaging with SDNs and related entities. Non-US individuals can also face consequences, including secondary sanctions, for providing “material support” to SDNs.
FinCEN Alert
On October 20, 2023, FinCEN issued an alert aimed at helping financial institutions identify funding sources for Hamas. The alert urges institutions to be diligent in identifying suspicious activity that could benefit Hamas.
The alert outlines various ways in which Hamas may receive funding, including support from Iran, private donations, global investments, diverting aid from legitimate charities, controlling border crossings and commerce routes, running racketeering business operations, extortion of local populations, and conducting fundraising campaigns involving virtual and fiat currency.
It also provides a list of red flags for financial institutions to detect and prevent suspicious activities related to Hamas funding.
If you have any specific questions about these actions or need further details, please let me know.
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