TAKEAWAYS
- The U.S. government has announced two rounds of sanctions targeting Hamas, other terrorist groups and Iranian networks following the October 7 attacks on Israel.
- The U.S. government is expected to continue to expand sanctions designations related to Hamas, Palestinian Islamic Jihad and their networks.
- U.S. officials have highlighted the need for careful due diligence to counter terrorist finance in this environment, including in relation to charitable organizations, virtual currency and FinTech.
Following the October 7 attack on Israel by Hamas, the Treasury Department’s Office of Foreign Assets Control (OFAC) has undertaken several initial sanctions steps to counter terrorist financing and call attention to financing networks, ongoing proliferation and terrorist support by Iran and due diligence expectations.
On October 18, 2023, OFAC imposed additional sanctions on 10 key Hamas terrorist group members, operatives and financial facilitators operating in Gaza, Sudan, Türkiye, Algeria and other countries. These sanctions, announced during President Biden’s visit to Israel, target Hamas’s financing network, Palestinian Islamic Jihad (PIJ) and tens of millions of dollars in diverted funds. Both Hamas and PIJ were formally designated by the State Department as terrorist organizations in October 1997. This action builds on OFAC’s May 2022 designation of officials and companies involved in managing Hamas’s secret international investment portfolio.
According to OFAC, those designated in this action “have operated under the guise of legitimate businesses and their representatives have attempted to conceal Hamas’s control over their assets. This investment network is directed by the highest levels of Hamas leadership and has allowed Hamas senior officials to live in luxury while ordinary Palestinians in Gaza struggle in harsh living and economic conditions.”
Specifically, the October 18 sanctions target operatives managing assets in a secret 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 on key Hamas-linked officials and financial networks. These sanctions target additional assets in Hamas’s investment portfolio, individuals who are facilitating sanctions evasion by Hamas-affiliated companies, and a Hamas official in Iran. Notably, these sanctions also designate members of Iran’s Islamic Revolutionary Guard Corps (IRGC), as well as a Gaza-based entity that has served as a conduit for illicit Iranian funds to Hamas and PIJ.
Impacted persons include the following:
Investment Portfolios
- Musa Muhammad Salim Dudin (Dudin) is a West Bank-based member of Hamas’s Political Bureau and Investment Office official. Following OFAC designation of Trend GYO as a Specially Designated Global Terrorist (SDGT) earlier this year, Dudin attempted to obfuscate Trend GYO’s continued affiliation with Hamas by transferring ownership to other parties and has worked directly with the senior leader of Hamas, Yahya Ibrahim Hassan Sinwar.
- Abdelbasit Hamza Elhassan Mohamed Khair (Hamza) is a Sudan-based Hamas financier who has managed numerous companies in Hamas’s investment portfolio. Hamza was previously involved in the transfer of almost $20 million to Hamas, some of which was sent directly to a senior Hamas financial officer, Mahir Jawad Yunis Salah, whom OFAC designated as an SDGT on September 10, 2015. He is CEO and beneficial owner of Sudan-based company Zawaya Group for Development and Investment Co. LTD and the Spain-based company Zawaya Group for Development Investment Sociedad Limitada. Hamza is also an indirect owner of Larrycom for Investment Company, a Sudan-based company. All three companies were designated by OFAC on October 27, 2023.
- Amer Kamal Sharif Alshawa (Alshawa), Ahmed Sadu Jahleb (Jahleb), Aiman Ahmad Al-Duwaik (al-Duwaik) and Walid Mohammed Mustafa Jadallah (Jadallah) are operatives of Hamas’s investment network in Türkiye and Algeria. Türkiye-based Alshawa is the chief executive officer for Trend GYO and has served as a board member on several Hamas investment portfolio companies. The October 27 designations added Alaeddin Senguler, Gulsah Yigidoglu and Arwa Mangoush, primary shareholders of Trend GYO.
Hamas Operatives
- Muhammad Ahmad ‘Abd Al-Dayim Nasrallah (Nasrallah) is a longtime Hamas operative based in Qatar with close ties to Iran and was involved in the transfer of tens of millions of dollars to Hamas, including Hamas’s military wing, the Izz al-Din al-Qassim Brigades.
- Ayman Nofal (Nofal), a member of the Izz al-Din al-Qassim Brigades, allegedly killed in an airstrike on October 17, is Hamas’s commander of military relations and serves as a member of the terrorist group’s General Military Council.
Iranian Supporters of Hamas
- Khaled Qaddoumi (Qaddoumi), a Jordanian national and longtime Hamas member, currently resides in Tehran and serves as Hamas’s representative to Iran.
- Ali Morshed Shirazi and Mostafa Mohammad Khani are Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF) officials who train and assist PIJ, Hamas and Hizballah.
- Ali Ahmad Faizullahi, is the Iran-based commander of the Saberin Special Forces Brigade of the IRGC Ground Force, which has been deployed to Syria and provided training to Hamas and Hizballah.
- Al-Ansar Charity Association (Al-Ansar) is a Gaza-based and PIJ-affiliated organization which ultimately provides funds that serve as a recruiting tool for terrorist activities.
- Nasser Al Sheikh Ali (Al Sheikh Ali) is director of PIJ-affiliated Al-Ansar.
Virtual Currency Fundraising
- Buy Cash Money and Money Transfer Company (Buy Cash), a virtual currency financial exchange providing money transfers and virtual currency exchange services, including Bitcoin, is based in Gaza. Israel’s National Bureau for Counter Terrorist Financing (NBCTF) seized several virtual currency wallets connected to Hamas fundraising campaigns, including some linked to the Izz al-Din Qassam Brigades. Ahmed M. M. Alaqad (Alaqad), Buy Cash’s owner and based in Gaza, registered Buy Cash’s domain in July 2015.
Iran-Related Sanctions
OFAC issued additional sanctions against Iranian actors who are enabling Iran’s destabilizing ballistic missile and unmanned aerial vehicle (UAV) programs. Those sanctioned include eight entities, one vessel and 11 individuals who have materially supported Iran’s IRGC, Ministry of Defense and Armed Forces Logistics (MODAFL), or their subordinates in the production and proliferation of missiles and UAVs. OFAC noted this action was taken as the UN’s restrictions on Iran’s missile-related activities under UN Security Council Resolution 2231 (UNSCR 2231) expire, in an effort to counter the threat posed by Iran’s procurement, development and proliferation of missiles, UAVs and other military weapons.
As noted above, the October 27 sanctions also included the sanctioning of a Hamas official residing in Iran, and members of Iran’s IRGC.
Increased Due Diligence
The October 18 designations followed remarks from the Under Secretary for Terrorism and Financial Intelligence, Brian Nelson, who stressed on October 17 that the Department of Treasury is dedicated to further disrupting Hamas’s financial network through a variety of tools, including anti-money laundering measures. Nelson noted that Hamas is a uniquely resourced terrorist group with several methods of accessing the formal financial system. In addition to significant financial support from Iran, revenue generated through secret investment portfolios, and extortionary practices surrounding border controls and local populations, Nelson highlighted that Hamas also receives donations from around the world. These donations are received directly or funneled through fictitious charitable organizations.
Nelson stressed that U.S. financial institutions can play a critical role in cutting off Hamas’s ability to access financing. Institutions can provide insight on how Hamas is attempting to reconstitute investment portfolios, open sham charities or exploiting virtual assets to draw in obscure funds. He encouraged financial institutions to continue flagging tips, leads, social media posts, account numbers and virtual currency wallet addresses.
Looking Ahead
The U.S. government is expected to continue to expand sanctions designations related to Hamas, PIJ and their networks and may consider sanctions designations and enforcement actions where parties have facilitated access to financial and military resources or enabled the evasion of U.S. sanctions.
