In response to the horrific attacks by the terrorist organization Hamas, FinCEN issued an alert on 10/20/2023 to financial institutions regarding the countering of funding to Hamas and its allies. Hamas gains funds through a variety of ways such as: support from Iran, private donations, global investment portfolios, racketeering, extortion of the local population, fundraising campaigns involving crypto currencies, and fictitious charities. Institutions must remain vigilant in checking the OFAC sanctions list for updates on individuals, entities, and nations known for harboring/assisting Hamas. OFAC has recently designated numerous Hamas members, operatives, and financial facilitators located in Gaza and elsewhere, including Sudan, Türkiye, Algeria, and Qatar. Additional due diligence should be requested for any transfers to these geographies. Watch for red flags such as someone attempting to conduct transactions with a sanctioned entity, information on the transaction that implies support for Hamas, uses virtual currency addresses that are known to be used by a terrorist organization, or a nonprofit organization (NPO) suspected of disseminating large funds to another NPO or multiple entities in quick succession.
More information on red flags, the formal alert, and FinCEN support can be found below:
FinCEN Article: FinCEN_Alert_Terrorist_Financing_FINAL508.pdf
Authors: Jeremy Clifton, CRCM CAMS and Nick Milcarek
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