Tuesday, November 11, 2014


When looking at the risk of unwittingly banking funds of a sanctioned terrorist organization, one must be aware that Turkey has become, in truth and in fact, a secondary headquarters for Hamas, which is a Specially Designated Global Terrorist (SDGT) organization by OFAC. When it came time for Hamas to admit responsibility for the deaths of three Israeli students last summer, the event which is considered the trigger for the recent Gaza conflict, that acknowledgement came from a senior Hamas leader based in Turkey. This is relevant to the threat level you face, when accepting wire transfers from Turkey.

Recently, allegations surfaced identifying $12m, reportedly under the control of Hamas leader Khaled Meshaal (a/k/a Abu Walid), and held by his brother-in-law, that was smuggled from Syria, and into Turkey, by a Hamas associate identified as Jabril Janid, though this may be a nomme de guerre. The funds, which were believed to be donation to Hamas, were later claimed to have been "lost" in the fog of the Syrian Civil War. Most likely, they were deposited in Turkish banks, and thereafter transferred to other financial institutions, at least some of which are in the EU, under the names of front companies or front men.

I bring this up because it has become increasing clear that Turkey has become a jurisdiction where Hamas funds are being held, as well as the personal accounts of corrupt Hamas leaders who have helped themselves to funds of the organization. Inasmuch as these are going to be substantial sums, your compliance staff should be alert to any unusual or unexplained transfers from Turkish banks, and obtain documented proof of Source of Funds, and Beneficial Ownership of the transferor, and transferee, companies involved. You do not want to be named as Hamas' banker in the media. 

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