Given that Hamas is a Specially Designated Global Terrorist organization (SGDT), you do not want any of its leaders, all of whom also qualify to be PEPs, due to their access to funds, opening accounts in your bank. The dangers have increased, due to the imminent funding of the Gaza Strip reconstruction program, and given Hamas' long track record of systemic corruption, and illicit diversion of donations and contributions, you can fully expect that a large amount of the donated funds will end up in the hands of Hamas' leadership. How else do you think that these corrupt PEPs became millionaires, with luxury homes, and vast wealth ?
Therefore, it is in your bank's best interest to set up a watch procedure that will profile possible HAMAS PEPs. Look for these red flags:
(1) A wealthy individual, of Arabic descent, who is interested in initiating a substantial account relationship with your bank.
(2) The currency will be US Dollars, either in the form of cash, or a wire transfer. If a wire, did it come from Turkey, Qatar, or the UAE ?
(3) the individual will have a passport indicating citizenship in Jordan, or another Middle East country, as there has never been an independent state of Palestine*. The place of birth of the person will be in a town or city located in present-day Israel, or infrequently the area of the West Bank. More rarely, it could be in another Middle Eastern country; Yassir Arafat was born in Cairo; his family came from both Egypt and Syria.
(4) Notwithstanding the previous item, the last name of the individual will show that he is from a family who originated in another part of the Middle East. Many Arab names are quite complex:
(a) Multiple first and middle names, often of family members who are deceased, or Islamic figures.
(b) The name of a clan.
(c) Lastly, the area of the family's origin. Most individuals who identify themselves as Palestinians are from families from other parts of the Middle East, and who emigrated into what is now Israel after 1925, and before 1948. Some of the most common country identifiers are, understanding that transliterating into English means that there are variations in spelling:
al-Masri Egyptian
el-Mughrabi Moroccan
el-Yamani Yemenite
al-Djazair Algerian
el-Baghdadi Baghdad, Iraq
Halabi Aleppo, Syria
al-Hussieni Syria
Tarabulsi Lebanon
Zoabi Iraq
(5) You can expect that the individual may pose as a prosperous businessman; you will, unfortunately, be unable to verify any financial information about his business operation, because it will be a carefully constructed cover occupation. Dig deep, and it will fall apart.
(6) Lastly, your staff has overheard what can only be described as a couple of words in Palestinian Arabic slang.
Any Hamas PEPs moving money into your bank have stolen or diverted it from badly-needed Gaza reconstruction programs. Do not risk any future terrorist financing, or providing material support to terrorism charges; keep Hamas out.
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* Notwithstanding claims of occupation, there has never been an independent state of Palestine. The British Mandate, 1920-1948, which included Jordan, took over from the Ottoman Empire, which collapsed at the end of the First World War. Jordan annexed what is today known as the West Bank, after the cease-fire between Israel and the defeated Arab armies, in 1948. Gaza was behind the Egyptian Army lines at cease-fire, and was administered by Egypt until the 1967 war.
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