Going after key elements of the Hamas European fundraising network on the anniversary of the Gaza war, on October 7 the U.S. Treasury Department’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 based in Gaza.
OFAC also designated a longstanding Turkey-based Hamas supporter and nine of his businesses. OFAC asserted that these actors play critical roles in external fundraising for Hamas, often under the guise of charitable work which finances the group’s terrorist activities.
Terrorists abusing non-profit organizations to raise cash
The new action, which was 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.
The Treasury Department has stated it is committed to exposing terrorists and terrorist organizations that abuse the NPO sector. By publicly identifying a sham charity, this new action reduces the overall risk of the NPO sector and helps preserve access by legitimate humanitarian organizations to financial services.
Secretary of the Treasury Janet L. Yellen declared “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.”
She also warned “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.”
A long history of anti-Hamas sanctions
The October 7 announcement is the eighth tranche of U.S. designations targeting Hamas’s financial support networks since the 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 U.S. 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.
Hamas’ exploitation of sham charities
Hamas has exploited the suffering in Gaza to solicit funds through sham and front charities that falsely claim they are helping 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 USD 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: Hamas Supporter
Hamid Abdullah Hussein al Ahmar (al Ahmar), a Yemeni national living in Turkey, 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 USD 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 by OFAC 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 also designated the following nine entities pursuant to E.O. 13224, as amended, for being owned, controlled, or directed by, directly or indirectly, al Ahmar:
Al Ahmar Trading Group, based in Yemen.
Al Ahmar Oils Supply and Distribution, based in Yemen.
Sama International Media, based in Yemen.
Al Salam Trading and Agencies General Establishment, based in Yemen.
Saba, Trade & Investment S.R.O., based in Czechia.
Sabafon International SAL (Offshore), based in Lebanon.
Sabaturk Dis Ticaret Anonim Sirketi, based in Turkey.
Vivid Enerji Yatirimlari Anonim Sirketi, based in Turkey.
Investrade Portfoy Yonetimi Anonim Sirketi, based in Turkey.
Hamas fundraisers based in Europe
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 fact 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 USD 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 leading 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 by OFAC 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-controlled Bank
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.
Sanctions implications
The individuals designated by OFAC above are not/not subject to immediate arrest, rather the new sanctions are primarily financial and freeze access to the U.S. financial system as well as “naming and shaming” the organizations.
As a result of the OFAC designations, 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. 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.