Sunday, October 12, 2014


The Government of Venezuela has announced that it will be hosting one thousand residents, from the Palestinian territory of Gaza, at its medical schools. One hundred Gazans, the initial group, has, according to Venezuelan announcements, already made the journey. The problem is, since Gaza is run by Hamas, a Specially Designated Global Terrorist group, what other activities will all these "medical students" engage in, while in Venezuela, and will American financial institutions, and corporate entities face increased risk of OFAC violations, through contact with Hamas agents seeking to engage them in business transactions ?

Why am I skeptical about the motives of these "Students ?"

 There is no common language which Venezuelan medical colleges could teach any Gaza residents in Venezuela. Spanish is not one of the languages in the known curriculum of Gaza schools, and medical school demands advanced proficiency in the language it is taught in. While there are a number of Arabic-speaking Venezuelans, only a small number are in the medical professions, and certainly not
as medical school professors.

The apparent nationality of the so-called students is a problem. As Palestine has never been an independent country*, many Palestinians hold Jordanian passports, and they could hold themselves out as such, when seeking to evade OFAC sanctions on Hamas. Also, given that 174 Venezuelan passports have reportedly shown up, in the Middle East, in the hands of Arab nationals who live there, expect some of the Hamas students to obtain legitimate Venezuelan passports, which is a direct threat to the US banks that do business with them.

Hamas, whose declared aim is the establishment of a state under Sharia law, will include, in the "student" population intelligence and security agents, both to control the small minority of true medical students, and for other Hamas aims and goals,  through criminal activities, which will certainly result in terrorist financing. Hezbollah has been funding its operations through Venezuelan-based crime for several years, so you can expect Hamas, to swiftly follow suit.

Therefore, compliance officers at US banks would to well to:
(1) Carefully examine any new clients holding Jordanian passports, coming from Latin American addresses, to insure that they are not truly Hamas operatives seeking to gain access to the American financial structure, through their bank. Where does the passport say they were born ? if anywhere in present-day Israel, and outside of Jordan, you have a potential OFAC problem, and (2) Non Spanish-speaking individuals, holding Venezuelan passports, seeking the same access. Where were they born ?

These 1000 Gaza residents will increase potential Country Risk levels for Venezuela; make sure that all compliance staff are aware of this new threat.

*Historical Note: The British Mandate of Palestine from 1920, which included all of present-day Israel and Jordan, was further divided in 1923, with most of the territory being designated as Jordan. If you know your history, you know that the post-World War I British colonial administration chose to designate the territory, taking a portion of the punitive name assigned to it by the Romans, which was "Syria Palestina," reportedly taken from the Phillistines, the ancient Greek inhabitants of the Mediterranean coastal area south of present-day Tel Aviv.

Most Arab nationals who have designated themselves as Palestinians trace their 20th-century roots  to Egypt or Arabia, which can often be ascertained from their last names. Jordan actually annexed the West Bank in 1950, and Egypt occupied Gaza. as it was on their side of the Armistice Line at the end of hostilities between the State of Israel and the invading armies of the Arab countries.


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