FINANCIAL INSTITUTIONS WARNED OF SUSPICIOUS ACTIVITY LINKED TO HAMAS FINANCING
Financial institutions worldwide have been alerted to identify and report suspicious transactions associated with Hamas’ financing activities.
US Treasury’s Designations
The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has designated numerous Hamas members, operatives, and financial facilitators in various countries, including Gaza, Sudan, Turkey, Algeria, and Qatar.
Red Flag Indicators
FinCEN, a bureau within the U.S. Department of the Treasury, has identified several red flag indicators to help detect potential suspicious activity related to Hamas’ terrorist financing activities:
- Conducting transactions with OFAC-designated entities and individuals
- Information included in a transaction indicating support for terrorist campaigns
- Transactions with Money Services Businesses or financial institutions operating in higher-risk jurisdictions tied to Hamas activity
- Cyber-related transactions with relevant technical indicators, such as suspicious IP addresses, email addresses, or digital asset addresses
Reporting Suspicious Activity
Financial institutions are advised to consider the totality of available facts and circumstances before determining that a behavior or transaction is suspicious. Any data or information that helps identify the activity as suspicious can be included in the Suspicious Activity Report (SAR) form.
Charitable Organizations and Non-Profit Organizations
The FinCEN alert also warns financial institutions to be cautious when dealing with charitable organizations or non-profit organizations (NPOs) that may be linked to Hamas’ terrorist activities. Red flags include:
- Soliciting donations without providing any charitable services
- Receiving large donations from unknown sources over a short period of time
- Sending significant wire transfers or checks to other charitable organizations or NPOs
SAR Instructions
Financial institutions are urged to reference this alert by including the key term “FIN-2023-TFHAMAS” in SAR field 2 and providing a narrative indicating a connection between the suspicious activity being reported and this alert.
FinCEN’s Analysis
The information contained in this alert is derived from FinCEN’s analysis of Bank Secrecy Act data, open-source reporting, and information provided by law enforcement partners.
Questions or Comments
Questions or comments regarding the contents of this alert should be sent to the FinCEN Regulatory Support Section at frc@fincen.gov.