On May 24, 2022, the US Department of the Treasury’s Office of Foreign Assets Control designated Usama Ali, the head of Hamas’s Investment Office, as well as a network of three financial facilitators and six Hamas-affiliated companies responsible for generating revenue for the group though the management of an international investment portfolio. According to OFAC, while Hamas’s Shura Council and Executive Committee exercised control and oversight over the international investment portfolio, the Investment Office along with a network that it oversaw was responsible for the day-to-day management of the portfolio. OFAC reports that the Investment Office managed assets worth more than $500 million, including companies operating in Sudan, Turkey, Saudi Arabia, Algeria and the United Arab Emirates.
The newly-designated individuals and entities were sanctioned pursuant to Executive Order 13224, as amended, which targets terrorists, leaders, and officials of terrorist groups for supporting terrorists or acts of terrorism. Hamas has been designated in the US as a Foreign Terrorist Organization since 1997, and was designated in 2001 as a Specially Designated Global Terrorist pursuant to EO 13224.
As a result of these designations, all property and interests in property of today’s 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 the designated persons. In addition, entities owned fifty percent or more by one or more designated persons are also blocked. Pursuant to EO 13224, as amended, foreign financial institutions that engage in certain transactions with today’s designees risk exposure to secondary sanctions. OFAC can also prohibit or restrict the opening or maintenance of US correspondent accounts or payable-through accounts by foreign financial institutions that knowingly facilitate any significant transactions on behalf of a Specially Designated Global Terrorist (SDGT).