On October 18, 2023, the US Department of the Treasury’s Office of Foreign Assets Control designated 10 key members, operatives and financial facilitators of the Hamas terrorist group located in several areas, including Gaza, Sudan, Türkiye, Algeria, and Qatar, following the terrorist attack on Isreal. The designations target 6 individuals involved in managing Hamas’s secret international investment portfolio and 2 long-time Hamas operatives. OFAC also designated Buy Cash Money and Money Transfer Company (“Buy Cash”), a Gaza-based business that provides money transfer and virtual currency exchange services, and its owner Ahmed M.M. Alaqad for their alleged involvement in Hamas fundraising activities and providing fund transfers for affiliates of other terrorist groups. OFAC reports that the designations were imposed in close coordination with US partners and allies as part of an ongoing effort by the US government to identify Hamas’s sources of revenue in the West Bank, Gaza and surrounding areas. OFAC also expressed its appreciation to members of the public who provided OFAC with tips related to Hamas fundraising activities, and OFAC encouraged anyone with information about possible sanctions violations to contact OFAC’s Compliance Hotline at OFAC_Feedback@Treasury.gov.
The designations were made pursuant to Executive Order 13224, as amended, which targets terrorist groups and their supporters. Hamas and several other Palestinian terrorist groups have been designated by the US Department of State as Foreign Terrorist Organizations since October 1997 and listed as Specially Designated Global Terrorists (“SDGTs”) since October 2001. As a result of these designations, all property and interests in property of the designees within the United States or within the possession or control of a US person are blocked, and US persons are generally prohibited from engaging in transactions involving designated persons. In addition, entities owned 50 percent or more by a designated person or entity are also blocked, and foreign financial institutions that knowingly conduct significant transactions for a designated person risk exposure to sanctions.