On January 22, 2024, the United States joined the United Kingdom and Australia to impose new sanctions on Hamas facilitators and officials. The US Department of the Treasury’s Office of Foreign Assets Control designated members of Hamas-affiliated networks that performed financial exchanges in Gaza, including cryptocurrency transfers from the Islamic Revolutionary Guard Corps-Qods Force (“IRGC-QF”) to Hamas and the Palestinian Islamic Jihad (“PIJ”). Among the new designees are members of the Shamlakh family who have served as key players for Hamas by using money changing companies that they own or control, including the newly-designated Al-Markaziya Li-Siarafa and the Arab China Trading Company, to transfer tens of millions of dollars from Iran to Hamas. OFAC also designated members of the Hirzallah family for allegedly using multiple exchanges under their control, including the newly-designated Herzallah Exchange — reportedly the primary money launderer for Hamas — to facilitate millions of dollars’ worth of fund transfers, including cryptocurrency transactions.
The OFAC designations were imposed pursuant to Executive Order 13224, as amended, which targets terrorist groups and their supporters. As a result of the designations, all property and interests in property of the designated persons 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 a designated person. Entities owned 50 percent or more by one or more blocked persons are also blocked.
On January 22, 2024, the UK government also announced the imposition of sanctions against key Hamas financiers, including Zuheir Shamlakh, who was concurrently designated by the United States. The Foreign, Commonwealth and Development Office reported that Shamlakh has been known as the Hamas’s “main money changer” since 2019 and has played a significant role in the group’s shift toward cryptocurrencies. He was also allegedly responsible for the movement of large sums of money from Iran to Hamas ahead of the October 7 attacks on Israel. The United Kingdom also designated key members of Hamas and the PIJ, including Hassan Al-Wardian, the senior leader of Hamas in the Bethlehem/West Bank region, and senior PIJ official Jamil Yusuf Ahmad Aliya. The designations were imposed pursuant to the Counter-Terrorism (International Sanctions) (EU Exit) Regulations 2019 (SI 2019/573), which subject listed persons to asset freezes, targeted arms embargoes, and travel bans in the United Kingdom.
On January 23, 2024, the Minister of Foreign Affairs of Australia announced the imposition of counter-terrorism financing sanctions upon twelve individuals and three entities with ties to Hamas, Hizballah and the PIJ. The sanctions targeted Hamas leaders, persons who have trained terrorist operatives, and individuals and entities that financially supported Hamas or facilitated the transfer of funds to Hamas. The Minister emphasized that it is a criminal offense in Australia to use or deal with the assets of a designated person or make assets available to them.