Monday, September 12, 2016


If you are closely watching the rhetoric coming from Black activist groups of late, you know that they have aligned themselves with Middle Eastern and Arab organizations, and as a result, are now making policy statements against Israel, in support of BDS (which is now illegal in several states), and proclaiming pro-Palestinian, anti-Israel, and at times, even anti-semitic, dogma.

These positions, which vilify Israel, and by derivation, Jews, claiming that Israel is a "colonial" usurper of its national territory, which cause the Black movement to lose credibility with mainstream Americans, as history teaches us that Arab Palestinians' arrival in the region they now claim only occurred in the twentieth century, but Biblical Israel existed 3500 years ago, and Jews have lived in what is now Israel, continuously, since that time. Arabs are native solely to the Arabian Peninsula, and not to any other area of the Middle East, or North Africa, where they themselves displaced the local indigenous populations; they are the only true colonial power in the region, not Israel. The other argument, that Israel is, like the US, racist, which has no basis in fact, when the country has two million Arabs living freely with its borders, is merely a restatement of Arab enmity towards Israel.

Somewhere, Dr. Martin Luther King, who was a strong supporter of a democratic Israel, which practices freedom of religion, and whose American Civil Rights struggle was supported by American Jewish organizations, is turning over in his grave; the present group of activists gets an "F" grade in Black History; they have forgotten their old friends. If you choose to move too far to the left, you may acquire strange bedfellows you will regret onboarding later.

You are free to agree, or disagree, with my interpretation of the the Arab-Israeli conflict, but here in the United States, financial institution compliance officers must deal with the looming and ever-present threat of terrorist financing, and the consequences of conducting transactions with individuals, or entities, labeled by OFAC as SDGT, or SDN, due to terrorist affiliations.

The fear is that, while becoming more and more enmeshed with their new Arab Palestinian allies, that one or more of the Black activist organizations will, knowingly, or unwittingly, accept funding from Hamas, the Palestinian Islamic Jihad, or other OFAC-sanctioned groups, through front organizations, or intermediaries, and by doing so, violate American sanctions, which prohibit any transactions with designated terrorist organizations.

Hamas, among others, has a long history of seeking to raise funds in the United States, through charitable entities that front for it. Remember the Holy Land Foundation for Relief and Development ? Making a contribution to an American activist group, through a front not publicly identified as such, is easier than you think, especially when the US-based group, eager to receive funds, will not be looking too closely as donors.

We do not even know whether all of the NGOs that comprise the Black activist groups have designated, full-time compliance officers, and access to commercial off-the-shelf databases of known terrorists, and OFAC-sanctioned, individuals and entities. Their records do not appear to be transparent, and perhaps they should be.

The bottom line: unless the Black activist organizations now adopt banking best practices AML/CFT compliance programs, there is a substantial risk that Hamas, or some other terrorist group, will drop in funding, with potentially harmful consequences, not only for the activists, but for their banks as well.  

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