OFAC Issues Additional Sanctions on Hamas

OFAC issued additional sanctions on networks of Hamas-affiliated financial exchanges, and financial facilitators that have played key roles in funds transfers "from the Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF) to Hamas and Palestinian Islamic Jihad (PIJ) in Gaza."

In the Press Release, OFAC stated that the designation were aimed at financial "facilitators" that enable monetary transfers and illicit use of cryptocurrency to fund Hamas terrorist activities referred to in E.O. 13224 ("Blocking Property and Prohibiting Transactions With Persons Who Commit, Threaten To Commit, or Support Terrorism"). The OFAC designations include (i) the "Shamlakh Network," (ii) the Herzallah Exchange network, and (iii) individuals identified as the key financial facilitators in those networks who control money flow from Iran to Hamas.

OFAC stated that the Hamas' designations were issued in concurrence with similar sanctions being placed on key Hamas leaders and facilitators by the United Kingdom and Australia targeting the financial infrastructure supporting Hamas. OFAC stated that the new designations follow a series of previous U.S. actions targeting sources of Hamas support and financing, targeting Hamas operatives and financial facilitators, and designating officials and companies involved in managing Hamas's secret international investment portfolio.

In a separate action, OFAC designated an Iraqi Airline and its CEO for their role in support of the Islamic Revolutionary Guard Corps-Qods Force ("IRGC-QF") and its proxy groups in Iraq, Syria and Lebanon. These designations include leaders and supporters of IRGC-QF's primary Iran-aligned militias in Iraq, known as Kata’ib Hizballah, and the business that transfers and launders its monies. OFAC stated that these militias are responsible for drone and missile attacks against U.S. personnel in Iraq and Syria since October 7, 2023.