The Interior Ministry of the Palestinian Territory of Gaza has reportedly mandated today that all foreigners wishing to enter the Gaza Strip must first obtain a visa, effective immediately. Whilst this new regulation will most likely delay entry for aid workers and charitable officers, as well as impose a fee for this service, it also poses a sanctions risk for non-governmental organisations, especially charities.
Charitable organisations that operate in the UK, EU, or US are bound not to deal directly with Hamas, as it is a Specially Designated Global Terrorist (SDGT) in the United States, and similarly sanctioned in Europe. How will charities avoid exposure to fines & penalties when they apply for visas ? What about the visa fees; how will they be paid, and will the act of doing so expose the charities' banks ?
Banks who clients are charities that render aid in the Gaza Strip may be well advised to create, through bank counsel, some sort of certificate of compliance, whereby the charity affirms that it is not, directly or indirectly, involved with Hamas, or any of its agencies and agents. Will this insulate you from regulatory fines and penalties ? We cannot say, but i know that if I was still a compliance officer, and my bank had NGO customers who disbursed aid in Gaza, I would want to reduce my risk.
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