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Financial Services Law Insights and Observations

OFAC announces Hamas sanctions

Financial Crimes OFAC Department of Treasury Of Interest to Non-US Persons SDN List Hamas OFAC Designations OFAC Sanctions

Financial Crimes

On May 24, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions against a Hamas finance official as well as an expansive network of three Hamas financial facilitators and six companies that have generated revenue for the terrorist group through the management of an international investment portfolio. According to OFAC, Hamas’s Investment Office, whose leadership oversees the sanctioned network, has assets totaling over $500 million, including companies operating in Sudan, Turkey, Saudi Arabia, Algeria, and the United Arab Emirates (UAE). As a result of the sanctions, all property and interests in property belonging to the sanctioned entities subject to U.S. jurisdiction are blocked and must be reported to OFAC. Additionally, any entities that are owned, directly or indirectly, 50 percent or more by one or more blocked person are also blocked. U.S. persons are generally prohibited from engaging in any dealings involving the property or interests in property of blocked or designated persons. The designated entities are also subject to secondary sanctions pursuant to Executive Order 13224, which authorizes OFAC to “prohibit or impose strict conditions on the opening or maintaining in the United States of a correspondent account or a payable-through account of a foreign financial institution that knowingly conducted or facilitated any significant transaction on behalf of a Specially Designated Global Terrorist.”