Compliance officers at US banks must always be alert for NGOs and nonprofits that may be linked to, or controlled by, Specially Designated Global Terrorist (SDGT) groups, especially Hamas, and Hezbollah, given a history of zero tolerance by Federal law enforcement agencies, due to terrorist financing threats.
Congressional testimony, given recently at a joint hearing before two committees of the House of Representatives, detailed two organizations involved in the anti-Israel Boycott, Divestment and Sanctions (BDS) campaign, whose staff included either individuals known to be connected to Hamas, or who formerly worked at organizations, either shut down, or held civilly liable for providing material financial support to Hamas, such as Holy Land Foundation, Islamic Association for Palestine, and KindHearts.
These organizations are:
(1) American Muslims for Palestine.
(2) Students for Justice in Palestine.
Banking any organization, or nonprofit entity, that promotes the BDS agenda, should only occur after a thorough Enhanced Due Diligence (EDD) investigation, including the identification of all members of the leadership, to ensure that they have not been linked to any SDGT, and frankly, the reputation damage that may occur, should your clients learn that these entities are bank clients, should deter you from banking them, period. From a risk-based approach, the threat posed by potential terrorist financing charges against the bank, far exceeds the possible community goodwill, and small profits to be earned, from such business. Banks that do not want to show up in negative newspaper stories, for banking purveyors of hatred and prejudice, should decline BDS groups.
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