Treasury Warns of More Hamas-Related Sanctions, Issues Red Flags
The U.S. is planning more actions, including sanctions, to try to cut Hamas off from the global financial system after the terrorist group’s killings in Israel earlier this month, said Brian Nelson, the Treasury Department’s undersecretary for terrorism and financial intelligence. Nelson, speaking during a meeting of the multilateral Terrorist Financing Targeting Center this week in Saudi Arabia, said the U.S. has “much more work to do” to build on its initial response, which has so far included new designations (see 2310180003 and 2310160054) and a new advisory to provide banks with guidance on countering Hamas financing.
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“This is just the beginning of much more to come,” Nelson said, telling a TFTC meeting of representatives from Bahrain, Kuwait, Oman, Qatar, Saudi Arabia and the United Arab Emirates that “we all have a key role to play in mobilizing a robust, coordinated response.”
Nelson said the TFTC “must redouble our efforts to deny terrorists access to funds” and “root out bad actors from across the global financial system.” But he also stressed that the U.S. will not look to block transactions meant to provide humanitarian aid to the people of Gaza, which is experiencing a humanitarian catastrophe in the region due to Israeli retaliatory airstrikes.
The U.S. is “committed to ensuring the flow of legitimate humanitarian aid can reach the people of Gaza,” Nelson said. “Across all of our sanctions programs, there are authorizations and licenses to allow for the flow of life-saving food, water, and medicine.”
The advisory recently issued by Treasury’s Financial Crimes Enforcement Network includes several red flags banks should monitor that may indicate Hamas-related terrorist financing, such as if customers or their counterparties conduct transactions “that contain a nexus to identifiers listed” for parties sanctioned by the Office of Foreign Assets Control. Those identifiers could include email addresses, physical addresses, phone numbers, passport numbers or virtual currency addresses.
Financial institutions also should monitor whether information included in a transaction between customers “indicates support for terrorist campaigns,” FinCEN said. They also should look out for customers conducting transactions with money services businesses that offer virtual currency services, operate in “higher-risk jurisdictions tied to Hamas activity” and are “reasonably believed or suspected to have lax” customer due diligence requirements.
Other red flags include a customer conducting transactions that involve shell companies or other businesses that have ties to Iran; a charitable organization or nonprofit that solicits donations but doesn’t appear to provide charitable services; a charitable group or nonprofit that receives large donations from an unknown source over a short period and then sends wire transfers to other charitable groups or nonprofits; and a customer conducting transactions with virtual currency addresses suspected of ties to “terrorist financing donation campaigns.”
FinCEN said financial institutions can reference this advisory in their suspicious activity reports by including “FIN-2023-TFHAMAS” in SAR field 2.