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10/18/2023

Following Terrorist Attack on Israel, Treasury Sanctions Hamas Operatives and Financial Facilitators | U.S. Department…

Following Terrorist Attack on Israel, Treasury Sanctions Hamas
Operatives and Financial Facilitators
October 18, 2023

WASHINGTON — Today, the U.S. Department of the Treasuryʼs O ice of Foreign Assets
Control (OFAC) imposed sanctions on ten key Hamas terrorist group members, operatives,
and financial facilitators in Gaza and elsewhere including Sudan, Türkiye, Algeria, and Qatar.
This action targets members managing assets in a secret Hamas investment portfolio, a
Qatar-based financial facilitator with close ties to the Iranian regime, a key Hamas
commander, and a Gaza-based virtual currency exchange and its operator. Todayʼs
designations are part of a continuous e ort by the United States to root out Hamasʼs sources
of revenue in the West Bank and Gaza and across the region and is taken in close coordination
with regional partners and allies. To date, Treasury has targeted nearly 1,000 individuals and
entities connected to terrorism and terrorist financing by the Iranian regime and its proxies,
including Hamas, Hizballah, and other Iran-aligned terrorist groups in the region.
“The United States is taking swi and decisive action to target Hamasʼs financiers and
facilitators following its brutal and unconscionable massacre of Israeli civilians, including
children,” said Secretary of the Treasury Janet L. Yellen. “The U.S. Treasury has a long history
of e ectively disrupting terror finance and we will not hesitate to use our tools against
Hamas. We will continue to take all steps necessary to deny Hamas terrorists the ability to
raise and use funds to carry out atrocities and terrorize the people of Israel. That includes by
imposing sanctions and coordinating with allies and partners to track, freeze, and seize any
Hamas-related assets in their jurisdictions.”
This action builds on OFACʼs May 2022 designation of o icials and companies involved in
managing Hamasʼs secret international investment portfolio, as well as dozens of sanctions
imposed on Hamas and its networks since the founding of Treasuryʼs O ice of Terrorism and
Financial Intelligence in 2004. In addition to the funds Hamas receives from Iran, its global
portfolio of investments generates vast sums of revenue through its assets, estimated to be
worth hundreds of millions of dollars, with companies operating in Sudan, Algeria, Türkiye, the
United Arab Emirates, and other countries. The companies in Hamasʼs portfolio have operated
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Following Terrorist Attack on Israel, Treasury Sanctions Hamas Operatives and Financial Facilitators | U.S. Department…

under the guise of legitimate businesses and their representatives have attempted to conceal
Hamasʼs control over their assets. This investment network is directed by the highest levels of
Hamas leadership and has allowed Hamas senior o icials to live in luxury while ordinary
Palestinians in Gaza struggle in harsh living and economic conditions.
Today, OFAC is designating six individuals associated with Hamasʼs secret investment
portfolio, two senior Hamas o icials, and a Gaza-based virtual currency exchange and its
operator. This action is taken pursuant to Executive Order (E.O.) 13224, as amended, which
targets terrorist groups and their supporters. Hamas, and other Palestinian terrorist groups
Palestinian Islamic Jihad (PIJ) and the Popular Front for the Liberation of Palestine (PFLP),
have each been designated by the Department of State as Foreign Terrorist Organizations
since October 1997. The groups have also been listed as Specially Designated Global Terrorists
(SDGTs) since October 2001.

HAMAS INVEST MENT PORT F OLIO
Musa Muhammad Salim Dudin (Dudin) is a West Bank-based member of Hamasʼs Political
Bureau and Investment O ice o icial and is responsible for negotiations to free Hamas
members in prison. Dudin has publicly represented and spoken on behalf of the terrorist
organization. In 2023, following OFACʼs designation of Trend GYO as an SDGT, Dudin
attempted to obfuscate Trend GYOʼs continued a iliation with Hamas by transferring
ownership to other parties. Dudin has also worked directly with designated Hamas senior
leader Yahya Ibrahim Hassan Sinwar. Additionally, Dudin has previously received tens of
thousands of dollars from Political Bureau Deputy Chief Salih al-Aruri. Dudin has used these
funds to purchase a variety of weapons for Hamas that were subsequently used in deadly
terrorist attacks that resulted in the deaths of Israeli soldiers. The Department of State
designated Yahya Ibrahim Hassan Sinwar as an SDGT August 27, 2015 and OFAC designated
Salih al-Aruri as a SDGT on September 10, 2015.
Abdelbasit Hamza Elhassan Mohamed Khair (Hamza) is a Sudan-based Hamas financier
who has managed numerous companies in Hamasʼs investment portfolio and was previously
involved in the transfer of almost $20 million to Hamas, including funds sent directly to Mahir
Jawad Yunis Salah, a senior Hamas financial o icer, whom OFAC designated as an SDGT on
September 10, 2015. Hamza has facilitated funds for Hamas through a network of large
companies in Sudan. The network used by Hamza to launder money and generate revenue for
Hamas includes Sudan-based Al Rowad Real Estate Development, which OFAC designated as
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Following Terrorist Attack on Israel, Treasury Sanctions Hamas Operatives and Financial Facilitators | U.S. Department…

an SDGT in OFACʼs May 24, 2022 sanctions action targeting Hamasʼs investment portfolio.
Hamza also has longstanding ties to terrorism financing, including historic ties to al-Qaʼida
and Usama bin Laden-linked companies in Sudan.
Amer Kamal Sharif Alshawa (Alshawa), Ahmed Sadu Jahleb (Jahleb), Aiman Ahmad AlDuwaik (al-Duwaik), and Walid Mohammed Mustafa Jadallah (Jadallah) are Hamas
operatives and are part of Hamasʼs investment network in Türkiye and Algeria. Türkiye-based
Alshawa is the Chief Executive O icer (CEO) for Trend GYO and has served as a board member
on several Hamas investment portfolio companies. Türkiye-based Jahleb serves as the Hamas
investment portfolio secretary and coordinates various activities for Hamas-controlled
companies and Hamas o icials. Algeria-based al-Duwaik is a senior Hamas investment
portfolio manager who, along with Türkiye-based Jadallah, also serves on the boards of
several investment portfolio companies.
Dudin and Hamza are being designated pursuant to E.O. 13224, as amended, for having acted
or purported to act for or on behalf of, directly or indirectly, Hamas. Alshawa, Jahleb, AlDuwaik, and Jadallah 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.

HAMAS OPERAT IVES
Muhammad Ahmad ʻAbd Al-Dayim Nasrallah (Nasrallah) is a longtime Hamas operative
based in Qatar with close ties to Iranian elements. In recent years, he was involved in the
transfer of tens of millions of dollars to Hamas, including Hamasʼs military wing, the Izz al-Din
al-Qassim Brigades.
Ayman Nofal (Nofal), a member of the Izz al-Din al-Qassim Brigades who was allegedly killed
in an airstrike on Tuesday, is the commander of military relations for Hamas and serves as a
member of the terrorist groupʼs General Military Council. Nofal has been involved in Hamasʼs
coordination with separate Palestinian factions in its terrorist attacks against Israel.
Nasrallah and Nofal are being designated pursuant to E.O. 13224, as amended, for having
acted or purported to act for or on behalf of, directly or indirectly, Hamas.

HAMAS VIRT UAL CURRENCY F UNDRAISING

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Following Terrorist Attack on Israel, Treasury Sanctions Hamas Operatives and Financial Facilitators | U.S. Department…

In June 2021, Israelʼs National Bureau for Counter Terrorist Financing seized a number of
virtual currency wallets in connection to a Hamas fundraising campaign, some of which were
linked to the Izz al-Din Qassam Brigades. One of the seized wallet addresses belongs to Buy
Cash Money and Money Transfer Company (Buy Cash), a Gaza-based business that provides
money transfer and virtual currency exchange services, including Bitcoin.
In addition to involvement in Hamas fundraising, Buy Cash has also been used to transfers
funds by a iliates in other terrorist groups. In September 2019, Buy Cashʼs Bitcoin wallet
19D1iGzDr7FyAdiy3ZZdxMd6ttHj1kj6WW received a Bitcoin transfer equivalent to over $2,000.
The transfer was facilitated by a Türkiye-based money services business operator and alQaʼida a iliate. Additionally, in 2017 a Buy Cash account was registered by individuals involved
in payment for procurement of large quantities of online infrastructure on behalf of the
Islamic State of Iraq and Syria (ISIS). Ahmed M. M. Alaqad (Alaqad), who is based in Gaza,
registered Buy Cashʼs domain in July 2015. Alaqad has acted as Buy Cashʼs representative and
is the owner of Buy Cash financial exchange.
Buy Cash 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, Hamas. Alaqad 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, Buy Cash.
Hamas o en relies on small-dollar donations, including through the use of virtual currency.
While individual amounts may vary, any information can help identify new investigative links
for law enforcement and help disrupt planned attacks. OFAC appreciates members of the
public who have tips related to Hamas fundraising, including information regarding Hamasʼ
on-line fundraising campaigns and specific information such as account numbers, and virtual
currency wallet addresses. OFAC encourages anyone with information about activities that do
not comply with sanctions to contact the OFAC Compliance Hotline
at OFAC_Feedback@Treasury.gov.

SANCT IONS IMPLICAT IONS
As a result of todayʼs action, all property and interests in property of the designated 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
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Following Terrorist Attack on Israel, Treasury Sanctions Hamas Operatives and Financial Facilitators | U.S. Department…

persons are also blocked. Unless authorized by a general or specific license issued by OFAC, or
exempt, OFACʼs 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 designated
or otherwise blocked persons.
In addition, financial institutions and other persons that engage in certain transactions or
activities with sanctioned entities and individuals may expose themselves to sanctions or be
subject to an enforcement action. The prohibitions include the making of any contribution or
provision of funds, goods, or services by, to, or for the benefit of any designated person, or
the receipt of any contribution or provision of funds, goods, or services from any such person.
The power and integrity of OFAC sanctions derive not only from OFACʼs ability to designate
and add persons to the 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, please refer to OFACʼs Frequently Asked
Question 897 here. For detailed information on the process to submit a request for removal
from an OFAC sanctions list, please click here.
Click here for more information on the individuals and entities designated today.
Additional Treasury resources on countering the financing of terrorism:
2022 National Terrorist Financing Risk Assessment
National Strategy for Combatting Terrorist and Other Illicit Financing
Action Plan to Address Illicit Financing Risks of Digital Assets
FATF Report: Virtual Assets Red Flag Indicators of Money Laundering and Terrorist
Financing
Terrorist Financing Targeting Center
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