Treasury Sanctions Hamas Crypto Fundraising Network Spanning Europe and Gaza
The US Treasury's Office of Foreign Assets Control has sanctioned a six-year fundraising operation that channelled more than $2 million to Hamas, with hundreds of thousands of dollars moving through cryptocurrency. The action names individuals based in France, two associated charities, and a senior Hamas military commander in Gaza. For accounting firms, auditors, and CFOs whose practices touch digital assets, the designation carries immediate, concrete compliance obligations that extend well beyond the named parties themselves.
What Treasury Actually Sanctioned
According to the Treasury Department, the network operated from 2020 through 2026, raising funds under the cover of purported humanitarian charities before routing money to Hamas's military wing. Treasury alleges that Faouzi Barika and Amel Oualid, both based in France, collected donations framed as humanitarian aid and then transferred those funds onward to Hamas, a group designated as a terrorist organisation across numerous jurisdictions including the United States, European Union, and United Kingdom.
The Crypto Component
Treasury was specific about one crypto-linked transaction stream: Barika and Oualid allegedly sent hundreds of thousands of dollars in cryptocurrency to Saleem Abdallah Saleem al-Zaq, identified as a deputy battalion commander in Hamas's Al-Qassam Brigades and based in Gaza. Treasury did not assert that the full $2 million moved in cryptocurrency. The broader picture is a hybrid network: conventional fundraising combined with crypto settlement to the end recipient.
Treasury noted separately that the Al-Qassam Brigades had previously advised donors to avoid sending funds directly from certain exchanges, and to use intermediate crypto services before transferring into TRON wallets. That operational detail matters for compliance professionals: it illustrates how sanctioned actors deliberately layer transactions across services to obscure the destination, a pattern that makes transaction-level screening inside your crypto accounting and reporting workflow indispensable.
Scale and Timing
Of the total amount raised, $1.5 million was collected after Hamas's October 7, 2023 attack on Israel, meaning the network accelerated its activity during a period of heightened international scrutiny. That acceleration, despite the scrutiny, is itself a red flag typology: urgency-driven fundraising spikes through charity channels following high-profile events.
Legal Mechanics: What the Designation Does
OFAC sanctions are not simply reputational. They carry hard legal consequences, and the scope of those consequences is broader than many finance teams appreciate.
Asset Freeze and Transaction Bar
Any property or interest in property belonging to the designated individuals and charities that falls under US jurisdiction is immediately blocked. US persons, which includes US-incorporated entities and their foreign branches, are generally prohibited from conducting any transaction with the designated parties. That prohibition covers direct payments, crypto transfers, and even facilitating such transactions by a third party.
Secondary Sanctions Exposure
Foreign financial institutions that knowingly facilitate significant transactions for designated parties face potential secondary sanctions risk. This is the provision that makes the designation globally relevant: a non-US accounting firm, exchange, or payment processor that processes a material transaction for a named party, even if it has no US operations, can find itself cut off from the US financial system. The threshold for "significant" is fact-specific, but regulators have interpreted it broadly in terror-finance cases.
The 50 Percent Rule
OFAC's ownership rule means that any entity owned 50% or more, directly or indirectly, by one or more designated parties is itself treated as sanctioned, even if not explicitly named. For firms onboarding corporate clients with complex ownership structures, this rule demands beneficial ownership verification that goes beyond a single layer of the cap table.
Why This Matters for Crypto Accounting and AML Workflows
This enforcement action fits a pattern Treasury has been developing for several years: treating cryptocurrency as one channel within a broader, multi-method terror finance network rather than as the primary mechanism. That framing has practical implications for how compliance teams should think about risk.
The Hybrid-Channel Problem
When conventional and crypto rails sit inside the same fundraising operation, a firm that screens only its fiat transactions or only its crypto transactions is working with an incomplete picture. The Hamas network allegedly used charity donation flows, presumably processed through conventional banking, alongside crypto transfers. Firms whose crypto bookkeeping software logs digital asset transactions in one silo while fiat flows sit in another should treat those silos as a control gap.
The TRON wallet detail is also worth noting from a technical standpoint. TRON-based USDT has appeared repeatedly in sanctions and enforcement actions involving illicit finance because it combines low transaction costs with high liquidity. Any digital asset accounting software deployment that handles TRON-based assets should carry appropriately calibrated screening against sanctions lists at the wallet address level, not just at the counterparty KYC layer. For a closer look at how firms should evaluate the on-chain risk providers sitting inside those workflows, see our analysis of the nine questions to ask every on-chain risk provider.
Charity and NGO Client Risk
The use of purported humanitarian charities as the fundraising front deserves special attention from accountants and auditors whose client base includes not-for-profit or charitable organisations. The two charities named in the OFAC action were apparently presented as legitimate humanitarian vehicles. Firms conducting audits or providing bookkeeping services to charities operating in conflict-adjacent geographies should apply enhanced due diligence, including verifying that donation flows are consistent with stated purposes and that outbound transfers have documented beneficiaries with verified identities.
Geographic Footprint of the Network
The operation spanned France, the United States (as the sanctioning jurisdiction), and Gaza. That three-geography footprint illustrates why sanctions compliance cannot be treated as a purely domestic concern. European-based accounting firms serving clients with any Middle Eastern or cross-border donor exposure should treat this action as a prompt to reassess their own AML screening coverage. The parallel with Japan's sanctions against Garantex is instructive: enforcement increasingly crosses jurisdiction lines, and secondary sanctions risk travels with the transaction, not with the firm's registered address.
Accounting and Reporting Implications
For Accounting Firms and Auditors
Firms providing audit, bookkeeping, or advisory services to clients that hold or transact in digital assets need to assess whether their client screening processes would catch a counterparty subsequently added to the OFAC Specially Designated Nationals list. A retroactive match, where a wallet address a client transacted with last year is today on the SDN list, does not automatically create liability, but it does create a disclosure and investigation obligation. Document your screening cadence and the list versions used at each point of review.
For clients that hold crypto on behalf of third parties, such as custodians, fund administrators, or payment processors, the blocked-property rule means you need a clear protocol for what happens operationally when a sanctioned address appears in a custody ledger. That protocol should be written, tested, and included in your AML compliance manual before the regulator asks to see it.
For CFOs and Finance Teams
If your treasury function holds stablecoins or other digital assets, the screening obligation is not just a compliance department problem. The CFO is typically a signing officer on material transactions, and OFAC does not distinguish between intentional and negligent violations when calculating civil penalties. Implement a pre-transaction screening step inside your treasury management or crypto bookkeeping software workflow, and make sure that step is logged with a timestamp and the list version used. That audit trail is your first line of defence in any subsequent regulatory inquiry.
CFOs at firms with European operations should also note that the France-based individuals in this action will likely face asset freezes under EU sanctions frameworks as well, given the EU's own Hamas designations. Dual-jurisdiction exposure is increasingly the norm in terror-finance cases.
Transaction Monitoring Red Flags
The Treasury Secretary's statement that Hamas "relies on sophisticated financial facilitators and fraudulent schemes designed to exploit the public" points to a specific typology: layered transactions through apparently legitimate entities. In practical terms, the red flags relevant to this case include donation-pattern spikes following geopolitical events, outbound crypto transfers to wallets in sanctioned or high-risk jurisdictions shortly after receiving inbound fiat donations, use of intermediate crypto services before final settlement, and TRON wallet addresses as end destinations in any chain that touches conflict-region beneficiaries.
Frequently Asked Questions
Does this OFAC action affect non-US accounting firms?
Yes. Secondary sanctions provisions mean that foreign financial institutions, including accounting and professional services firms that handle financial transactions, can face consequences for knowingly facilitating significant transactions with designated parties. "Knowingly" is a fact-specific standard, but regulators have applied it broadly in terror-finance contexts. The safest approach is to treat OFAC designations as globally relevant screening triggers regardless of where your firm is registered.
Are TRON wallets inherently higher risk under sanctions rules?
No blockchain protocol is inherently sanctioned. The elevated attention on TRON-based assets in enforcement actions reflects the operational preferences of certain illicit actors, not a regulatory designation of the network itself. That said, compliance teams should ensure their screening tools cover TRON wallet addresses with the same rigour applied to Bitcoin or Ethereum addresses, particularly for stablecoin flows.
What does the 50 percent ownership rule mean for client onboarding?
OFAC's rule treats any entity that is 50% or more owned by a designated party as itself sanctioned, even if not named in a specific designation. During client onboarding, beneficial ownership verification must therefore look through corporate layers to identify any natural person or entity on the SDN list. A single-layer company search is not sufficient for high-risk client categories.
How should firms handle a retroactive SDN list match on a past transaction?
A match discovered after the fact does not automatically create liability, but it does trigger an obligation to investigate and potentially to file a Suspicious Activity Report or equivalent under your jurisdiction's AML rules. Document the discovery date, the nature of the transaction, and the steps taken to investigate. If the transaction was material or the match is clear, consider engaging legal counsel before taking any further steps, including any voluntary disclosure to OFAC.
Does this action change how charity clients should be treated for AML purposes?
Charities operating in or near conflict zones, or those soliciting donations related to conflict-affected populations, should already be classified as higher-risk clients under most AML frameworks. This action reinforces that classification. For auditors and accountants serving such clients, enhanced due diligence should include reviewing the stated purpose of outbound transfers, the identity of beneficiary organisations, and whether transaction patterns are consistent with the charity's publicly stated mission.
Source: CoinDesk Policy