Key Takeaways:
The U.S. government has recently implemented sanctions against Hamas, other terrorist groups, and Iranian networks in response to the October 7 attacks on Israel.
These sanctions are part of ongoing efforts to counter terrorist financing and raise awareness of financial networks supporting terrorism.
U.S. officials emphasize the importance of due diligence to combat terrorist financing, including with respect to charitable organizations, virtual currency, and FinTech.
In response to the October 7 attack on Israel by Hamas, the Treasury Department’s Office of Foreign Assets Control (OFAC) has taken several initial steps to address terrorist financing and shed light on financing networks. These actions also highlight ongoing proliferation and terrorist support by Iran, as well as expectations for due diligence.
On October 18, 2023, OFAC imposed additional sanctions targeting ten key members, operatives, and financial facilitators associated with the Hamas terrorist group. These individuals operated in various countries, including Gaza, Sudan, Türkiye, Algeria, and others. These sanctions aim to disrupt Hamas’s financing network, as well as the Palestinian Islamic Jihad (PIJ) and significant diverted funds. Both Hamas and PIJ were officially designated as terrorist organizations by the U.S. State Department in October 1997. These sanctions build upon OFAC’s previous designation in May 2022 of officials and companies managing Hamas’s secret international investment portfolio.
According to OFAC, those named in these sanctions have been involved in legitimate businesses while attempting to conceal Hamas’s control over their assets. This investment network is directed by senior Hamas leadership and has enabled senior Hamas officials to live lavishly, while ordinary Palestinians in Gaza face challenging living and economic conditions.
Specifically, the October 18 sanctions target individuals managing assets in a concealed Hamas investment portfolio, a Persian Gulf financial facilitator with close ties to the Iranian regime, a key Hamas commander, and a virtual currency exchange operating in the Gaza Strip.
On October 27, 2023, OFAC announced a second round of sanctions targeting additional Hamas-linked officials and financial networks. These sanctions focus on additional assets within Hamas’s investment portfolio, individuals facilitating sanctions evasion for Hamas-affiliated companies, and a Hamas official in Iran. Importantly, these sanctions also encompass members of Iran’s Islamic Revolutionary Guard Corps (IRGC) and a Gaza-based entity that has facilitated illicit Iranian funds to Hamas and PIJ.
Individuals and entities impacted by these sanctions include:
Investment Portfolios:
- Musa Muhammad Salim Dudin (Dudin): A member of Hamas’s Political Bureau based in the West Bank and an official of the Investment Office.
- Abdelbasit Hamza Elhassan Mohamed Khair (Hamza): A Hamas financier based in Sudan who managed several companies in Hamas’s investment portfolio.
- Amer Kamal Sharif Alshawa (Alshawa), Ahmed Sadu Jahleb (Jahleb), Aiman Ahmad Al-Duwaik (al-Duwaik), and Walid Mohammed Mustafa Jadallah (Jadallah): Operatives of Hamas’s investment network in Türkiye and Algeria.
Hamas Operatives:
- Muhammad Ahmad ‘Abd Al-Dayim Nasrallah (Nasrallah): A longtime Hamas operative based in Qatar with close ties to Iran.
- Ayman Nofal (Nofal): A member of the Izz al-Din al-Qassim Brigades, allegedly killed in an airstrike on October 17, and Hamas’s commander of military relations.
Iranian Supporters of Hamas:
- Khaled Qaddoumi (Qaddoumi): A Jordanian national and longtime Hamas member residing in Tehran, serving as Hamas’s representative to Iran.
- Ali Morshed Shirazi and Mostafa Mohammad Khani: Officials of the Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF) who support PIJ, Hamas, and Hizballah.
- Ali Ahmad Faizullahi: The Iran-based commander of the Saberin Special Forces Brigade of the IRGC Ground Force, which has provided training to Hamas and Hizballah.
Al-Ansar Charity Association (Al-Ansar):
A Gaza-based and PIJ-affiliated organization providing funds that are used as a recruiting tool for terrorist activities.
Nasser Al Sheikh Ali (Al Sheikh Ali):
Director of PIJ-affiliated Al-Ansar.
Virtual Currency Fundraising:
- Buy Cash Money and Money Transfer Company (Buy Cash): A virtual currency financial exchange based in Gaza, providing money transfers and virtual currency exchange services, including Bitcoin.
Iran-Related Sanctions:
OFAC also imposed sanctions on Iranian actors supporting Iran’s ballistic missile and unmanned aerial vehicle (UAV) programs.
Increased Due Diligence:
The October 18 designations align with remarks from Under Secretary for Terrorism and Financial Intelligence, Brian Nelson, who emphasized on October 17 the Department of Treasury’s commitment to disrupting Hamas’s financial network through various tools, including anti-money laundering measures. Nelson highlighted that Hamas has multiple methods of accessing the formal financial system, including financial support from Iran, revenue from secret investment portfolios, and exploitation of border controls and local populations through extortion. He also noted that Hamas receives donations from around the world, sometimes through fictitious charitable organizations.
Nelson encouraged U.S. financial institutions to play a crucial role in cutting off Hamas’s access to financing by reporting suspicious activities related to investment portfolios, sham charities, and virtual assets.
Looking Ahead:
The U.S. government is expected to continue expanding sanctions related to Hamas, PIJ, and their networks. Additionally, it may consider sanctions and enforcement actions against parties facilitating access to financial and military resources for these groups or enabling the evasion of U.S. sanctions.
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