WASHINGTON — Today, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) is taking action against Hamas’s covert links to nonprofit organizations. Hamas’s insidious practice of operating behind civilian organizations endangers Palestinians and undermines efforts to build a lasting and prosperous peace. By exposing organizations with secret ties to Hamas, OFAC is strengthening the international community’s ability to support legitimate Palestinian interests.
“Hamas continues to show a callous disregard for the welfare of the Palestinian people,” said Under Secretary of the Treasury for Terrorism and Financial Intelligence John K. Hurley. “The Trump Administration will not look the other way while Hamas leadership and enablers exploit the financial system to fund terrorist operations.”
Today’s action targets six Gaza-based organizations that claim to provide medical care to Palestinian civilians but in fact support the military wing of Hamas, the Izz al-Din al-Qassam Brigades. The fraudulent nature of these organizations, which use deception to raise funds from international donors, demonstrates Hamas’s perfidy and deprives innocent civilians of the medical care they need. OFAC is also targeting the Popular Conference for Palestinians Abroad, an organization that purports to broadly represent Palestinians but is clandestinely controlled by Hamas and has been a key backer of several so-called flotillas attempting to access Gaza.
Today’s action is being taken pursuant to the counterterrorism authority, Executive Order (E.O.) 13224, as amended. On October 31, 2001, the U.S. Department of State designated Hamas pursuant to E.O. 13224 for having committed, or posing a significant risk of committing, acts of terrorism that threaten the security of U.S. nationals, or the national security, foreign policy, or economy of the United States. Hamas is also designated as Foreign Terrorist Organizations pursuant to section 219 of the Immigration and Nationality Act.
HAMAS-AFFILIATED ORGANIZATIONS IN GAZA
Hamas secretly operates a network of organizations in Gaza that purport to be independent but are subordinate to the Hamas military wing. Similar to the U.S.-designated al-Weam Charitable Society, these groups hide their affiliation to Hamas in order to raise funds from overseas donors, many of whom are unwitting, and thereby divert donations intended for the Palestinian people to enable Hamas’s terrorism.
As part of Treasury’s commitment to safeguard the humanitarian sector and enable the continued provision of humanitarian aid to the Palestinian people, OFAC is exposing six Gaza-based organizations that support Hamas’s military wing, as revealed by documentary evidence taken from Hamas offices after October 7, 2023. The purpose of these designations is to help reduce the overall terrorist financing risk in the charitable non-profit organization sector by informing the public about financing networks operating in support of terrorist organizations and activities. This action aims to enable the continued provision of humanitarian aid to Gaza—subject to OFAC’s humanitarian general licenses—by raising the public’s awareness of these Hamas-controlled organizations, especially as the international community begins to build up a stabilization force for the Gaza Strip.
The Gaza-based organizations Waed Society Gaza (Waed Society), Al-Nur Society Gaza (Al-Nur), Qawafil Society Gaza (Qawafil), Al-Falah Society Gaza (Al-Falah), Merciful Hands Gaza (Merciful Hands), and Al-Salameh Society Gaza (Al-Salameh) are organized by, and integrated into, Hamas’s military wing. Members of Hamas’s internal security forces are formally assigned to work in these so-called charities, specifically the Waed Society and Al-Salameh. Documentary evidence captured from Hamas also shows that Hamas provides its fighters with detailed instructions on how they must navigate the group’s own bureaucracy to formally request their affiliated organizations provide their fighters with specific projects and services.
The Waed Society receives funding directly from Hamas to execute Hamas projects in Gaza and is tasked by the Hamas military wing to advocate on behalf of Hamas fighters that have been captured fighting the Israeli Defense Forces. It also receives direct funding from Hamas to conduct specific projects.
Al-Nur and Al-Falah are similarly funded and have directly transferred money to the Hamas military wing. For example, funds from Al-Nur are used to pay Hamas military wing members as well as provide services to Hamas fighters. Al-Falah similarly provides monetary support to Hamas. This includes direct financial transfers to the Hamas military wing, including over $2.5 million in funding that Al-Falah transferred to Hamas over a recent three-year period.
Merciful Hands is similarly controlled by the Hamas military wing. Some Merciful Hands funding, as well as specific instructions for its operations, are provided by the Hamas military wing. Al-Salameh, and Qawafil are similarly tasked and funded by Hamas to provide support for the organization and complete projects that are intended to benefit Hamas.
The Waed Society Gaza, Al-Nur Society Gaza, Qawafil Society Gaza and Al-Falah Society Gaza are being designated pursuant to E.O. 13224, as amended, for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, Hamas.
Merciful Hands Gaza and Al-Salameh Society Gaza are being designated pursuant to E.O. 13224, as amended, for being owned, controlled, or directed by, or for having acted or purported to act for or on behalf of, directly or indirectly, Hamas.
HAMAS FRONT ORGANIZED FLOTILLAS
The Popular Conference for Palestinians Abroad (PCPA) is a main organizer of recent flotillas that sought to break Israel’s security cordon around Gaza. The PCPA is also clandestinely acting on behalf of Hamas. As a front organization for Hamas, it operates in accordance with Hamas directives and was established and managed by operatives from Hamas’s Bureau of International Relations, which at the time was led by Mussa Abu Marzouq.
On April 19, 2018, Ismail Haniyeh signed a letter addressed to the Hamas Political Bureau that outlined his guidance for how Hamas should take control over the Palestinian political process. One element of this plan was to escalate violence against Israel. The other was to boost Hamas’s international outreach, with the PCPA identified as a core part of this strategy. However, Hamas’s links to the PCPA predated Haniyeh’s letter. Hamas also helped fund the inaugural meeting of the PCPA and provided $100,000 for this conference. The goal of the PCPA, and the reason behind Hamas’s secret links to the organization, is for Hamas to clandestinely expand its political influence through a group that purportedly represents the interests of the Palestinian diaspora.
The PCPA does not only work with, and in support of, Hamas—it operates at Hamas’s behest. The strategic and tactical aspects of the PCPA’s activity are controlled by Hamas through the placement of key Hamas-linked figures in major positions throughout the organization. Two examples of this are Adel Saad al-Din Hassan Doughman (Doughman) and Majid Khalil Moussa al-Zeer (al-Zeer), both of whom were designated by Treasury on October 7, 2024. Doughman, who held a key position in the PCPA, is one of the most prominent Hamas representatives in Europe and led Hamas’s efforts in Austria. Al-Zeer, who served as the Chairman and President of the PCPA, as well as other senior positions, plays a central role in Hamas’s fundraising efforts in Europe and was the senior Hamas representative in Germany.
OFAC is also designating Zaher Khaled Hassan Birawi (Birawi), a United Kingdom-based individual who is a senior official of the PCPA, a member of its General Secretariat, and one of the founding members of the PCPA. The General Secretariat of the PCPA provides executive leadership and direction to the PCPA. Members of the PCPA General Secretariat, as well as those in leadership positions of the PCPA’s various regional bodies, especially any U.S. persons, should be aware of the sanctions risk they are incurring by any continued support to this now-sanctioned organization.
Members of the Palestinian diaspora have a right to gather and advocate for their legitimate political concerns. Members of the international community, including U.S. persons, also have a right to support these efforts. Consistent with OFAC FAQ 1190, OFAC does not sanction persons for their engagement in activities subject to U.S. constitutional protection, such as protected speech or religious practice or for their religious beliefs. It is Hamas, through their insidious strategy of hiding behind civilians while using terrorism to attempt to achieve political aims, both in Gaza and abroad, that puts innocent lives at risk and undermines international efforts to build a lasting peace and a prosperous future for all Palestinians.
The Popular Conference for Palestinians Abroad is being designated pursuant to E.O. 13224, as amended, for being owned, controlled, or directed by, or for having acted or purported to act for or on behalf of, directly or indirectly, Hamas.
Zaher Khaled Hassan Birawi is being designated pursuant to E.O. 13224, as amended, for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, the PCPA.
SANCTIONS IMPLICATIONS
As a result of today’s action, all property and interests in property of the designated or blocked persons described above that are in the United States or in the possession or control of U.S. persons are blocked and must be reported to OFAC. In addition, any entities that are owned, directly or indirectly, individually or in the aggregate, 50 percent or more by one or more blocked persons are also blocked. Unless authorized by a general or specific license issued by OFAC, or exempt, OFAC’s regulations generally prohibit all transactions by U.S. persons or within (or transiting) the United States that involve any property or interests in property of blocked persons.
Violations of U.S. sanctions may result in the imposition of civil or criminal penalties on U.S. and foreign persons. OFAC may impose civil penalties for sanctions violations on a strict liability basis. OFAC’s Economic Sanctions Enforcement Guidelines provide more information regarding OFAC’s enforcement of U.S. economic sanctions. In addition, financial institutions and other persons may risk exposure to sanctions for engaging in certain transactions or activities involving designated or otherwise blocked persons. The prohibitions include the making of any contribution or provision of funds, goods, or services by, to, or for the benefit of any designated or blocked person, or the receipt of any contribution or provision of funds, goods, or services from any such person. Individuals located in the U.S. or abroad who provide information about sanctions violations to Treasury’s Financial Crimes Enforcement Network (FinCEN) whistleblower incentive program may be eligible for awards if the information they provide leads to a successful enforcement action that results in monetary penalties exceeding $1,000,000. FinCEN is currently accepting whistleblower tips.
Furthermore, engaging in certain transactions involving the persons designated today may risk the imposition of secondary sanctions on participating foreign financial institutions. OFAC can prohibit or impose strict conditions on opening or maintaining, in the United States, a correspondent account or a payable-through account of a foreign financial institution that knowingly conducts or facilitates any significant transaction on behalf of a person who is designated pursuant to the relevant authority.
The power and integrity of OFAC sanctions derive not only from OFAC’s ability to designate and add persons to the Specially Designated Nationals and Blocked Persons List (SDN List), but also from its willingness to remove persons from the SDN List consistent with the law. The ultimate goal of sanctions is not to punish, but to bring about a positive change in behavior. For information concerning the process for seeking removal from an OFAC list, including the SDN List, or to submit a request, please refer to OFAC’s guidance on Filing a Petition for Removal from an OFAC List.
Click here for more information on the persons designated today.