WASHINGTON — Today, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated three individuals and one sham charity that are prominent international financial supporters of Hamas, as well as one Hamas-controlled financial institution in Gaza. OFAC also designated a longstanding Hamas supporter and nine of his businesses. These actors play critical roles in external fundraising for Hamas, often under the guise of charitable work, that finance the group’s terrorist activities. Today’s action, which is being taken pursuant to the counterterrorism authority Executive Order (E.O.) 13224, as amended, highlights the abuse of the non-profit organization (NPO) sector by terrorist financiers through the use of sham charities to generate revenue.
“As we mark one year since Hamas’s brutal terrorist attack, Treasury will continue relentlessly degrading the ability of Hamas and other destabilizing Iranian proxies to finance their operations and carry out additional violent acts,” said Secretary of the Treasury Janet L. Yellen. “The Treasury Department will use all available tools at our disposal to hold Hamas and its enablers accountable, including those who seek to exploit the situation to secure additional sources of revenue.”
Treasury is committed to exposing terrorists and terrorist organizations that abuse the NPO sector. By publicly identifying a sham charity, this action reduces the overall risk of the NPO sector and helps preserve access by legitimate humanitarian organizations to financial services.
Today’s action is the eighth tranche of U.S. designations targeting Hamas’s financial support networks since the horrifying terrorist attack of October 7, 2023. This includes an April 12, 2024 action sanctioning Hamas cyber actors, and October 18, 2023 and October 27, 2023 actions targeting sources of Hamas financing and financial facilitators. The United States continues to closely coordinate with its partners in targeting Hamas, including a joint designation with Australia and the United Kingdom on January 22, 2024 that targeted Hamas financial facilitators, as well as three actions with the United Kingdom on March 27, 2024, December 13, 2023, and November 14, 2023 targeting Hamas leaders and financiers.
The United States remains committed to working with our key partners and allies to counter the terrorist threats or terrorist organizations in the region. These designations were also enabled by key analysis and information from Treasury’s Financial Crimes Enforcement Network (FinCEN).
Hamas has exploited the suffering in Gaza to solicit funds through sham and front charities that falsely claim to help civilians in Gaza. Hamas affiliates raise funds through sham or front charities and also seek to garner public support for the group. As of early 2024, Hamas may have received as much as $10 million a month through such donations. Hamas considers Europe to be a key source of fundraising and has maintained representation across the continent for many years in part to raise funds through sham charities.
Hamid Abdullah Hussein al Ahmar (al Ahmar), a Yemeni national living in Türkiye, is one of the most prominent international supporters of Hamas. He is a key member of Hamas’s once-secret investment portfolio, which at its peak managed over $500 million worth of assets enabling Hamas’s leaders to live in luxury outside the Palestinian territories despite the real humanitarian needs of the people of Gaza. Since at least 2013, Al Ahmar has also been the chairman of the Lebanon-based Hamas sham charity Al-Quds International Foundation, which OFAC designated in October 2012 for being controlled by Hamas.
Al Ahmar is being designated pursuant to E.O. 13224, as amended, for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, Hamas. Al Ahmar is also being designated pursuant to E.O. 13224, as amended, for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, Al-Quds International Foundation.
OFAC is also designating the following nine entities pursuant to E.O. 13224, as amended, for being owned, controlled, or directed by, directly or indirectly, al Ahmar:
Mohammad Hannoun (Hannoun) is an Italy-based Hamas member who established the Charity Association of Solidarity with the Palestinian People, or Associazione Benefica di Solidarietà con il Popolo Palestinese (ABSPP), a sham charity in Italy which ostensibly raises funds for humanitarian purposes, but in reality helps bankroll Hamas’s military wing. As an executive at ABSPP, Hannoun has sent money to Hamas-controlled organizations since at least 2018. He has solicited funding for Hamas with senior Hamas officials and sent at least $4 million to Hamas over a 10-year period.
Majed al-Zeer (al-Zeer) is the senior Hamas representative in Germany, who is also one of the senior Hamas members in Europe and has played a central role in the terrorist group’s European fundraising. He has appeared publicly with other senior Hamas members in order to generate funding and other support for Hamas. Al-Zeer has also served in Hamas delegations in the Middle East along with Adel Doughman and Hannoun.
Adel Doughman (Doughman) is in charge of Hamas activity in Austria and is another one of the most prominent Hamas representatives in Europe. He has been closely associated with senior Hamas leaders and has held senior positions in institutions affiliated with Hamas, which transfer money to the organization. Doughman participates in conferences and delegations on behalf of Hamas and works with other institutions designated by the United States for their affiliation with Hamas, to include Union of Good and the al-Quds International Institution.
Hannoun and ABSPP are being designated for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services in support of, Hamas.
Al-Zeer and Doughman are being designated for having acted or purported to act for or on behalf of, directly or indirectly, Hamas.
Hamas uses unlicensed banks, like Al-Intaj Bank (Al-Intaj), to continue to fund internal operations and to skirt international sanctions by operating outside the international financial system. Founded in 2013, Al-Intaj is an unlicensed Hamas-run bank in Gaza that provides financial services for Hamas despite not being connected to international banks. The Palestine Monetary Authority did not provide a license for this bank to operate; instead, the bank received a permit from the Hamas-led administration in Gaza.
Al-Intaj is being designated pursuant to E.O. 13224, as amended, for being owned, controlled, or directed by, directly or indirectly, Hamas.
As a result of today’s action, all property and interests in property of the designated persons described above, and of any entities that are owned directly or indirectly, 50 percent or more by them, individually, or with other blocked persons, that are in the United States or in the possession or control of U.S. persons are blocked and must be reported to OFAC. Unless authorized by a general or specific license issued by OFAC, or exempt, OFAC’s regulations generally prohibit all transactions by U.S. persons or within (or transiting) the United States that involve any property or interests in property of designated or otherwise blocked persons.
U.S. persons must comply with OFAC regulations, including all U.S. citizens and permanent resident aliens regardless of where they are located, all persons within the United States, and all U.S.-incorporated entities and their foreign branches. Non-U.S. persons are also subject to certain OFAC prohibitions. For example, non-U.S. persons are prohibited from causing or conspiring to cause U.S. persons to wittingly or unwittingly violate U.S. sanctions, as well as engaging in conduct that evades U.S. sanctions. Violations of OFAC regulations may result in civil or criminal penalties.
In addition, non-U.S. financial institutions and other persons that engage in certain transactions or activities with sanctioned entities and individuals may expose themselves to sanctions risk or be subject to an enforcement action. The prohibitions include the making of any contribution or provision of funds, goods, or services by, to, or for the benefit of any designated person, or the receipt of any contribution or provision of funds, goods, or services from any such person.
OFAC may impose civil penalties for sanctions violations based on strict liability, meaning that a person subject to U.S. jurisdiction may be held civilly liable even if such person did not know or have reason to know that it was engaging in a transaction that was prohibited under sanctions laws and regulations administered by OFAC. OFAC’s Economic Sanctions Enforcement Guidelines provide more information regarding OFAC’s enforcement of U.S. economic sanctions, including the factors that OFAC generally considers when determining an appropriate response to an apparent violation. For additional information on complying with U.S. sanctions and export control laws, please see Department of Commerce, Department of the Treasury, and Department of Justice Tri-Seal Compliance Note.
Furthermore, engaging in certain transactions with the individuals designated today entails risk of secondary sanctions pursuant to E.O. 13224, as amended. Pursuant to this authority, OFAC can prohibit or impose strict conditions on the opening or maintaining in the United States of a correspondent account or a payable-through account of a foreign financial institution that knowingly conducted or facilitated any significant transaction on behalf of a Specially Designated Global Terrorist.
The power and integrity of OFAC sanctions derive not only from OFAC’s ability to designate and add persons to the Specially Designated Nationals and Blocked Persons (SDN) List, but also from its willingness to remove persons from the SDN List consistent with the law. The ultimate goal of sanctions is not to punish, but to bring about a positive change in behavior. For information concerning the process for seeking removal from an OFAC list, including the SDN List, please refer to OFAC’s Frequently Asked Question 897 here. For detailed information on the process to submit a request for removal from an OFAC sanctions list, please click here.
Treasury remains committed to enabling the flow of legitimate humanitarian assistance supporting the basic human needs of vulnerable populations, while continuing to deny resources to malicious actors. Accordingly, OFAC sanctions programs contain provisions for legitimate humanitarian support to vulnerable populations, including authorizations for certain humanitarian transactions in support of nongovernmental organizations’ activities. For more information, please review relevant authorizations and guidance on OFAC’s website.
Click here for more information on the persons designated today.
Additional Treasury resources on countering the financing of terrorism and providing humanitarian assistance to the Palestinian people:
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