COMPLIANCE OFFICERS FACING ZERO TOLERANCE FOR PERMITTING TERRORIST FINANCING INTO THE MIDDLE EAST NEED TO KNOW WHO THEIR ADDITIONAL ADVERSARIES ARE

Given what appears to be a renewed zero tolerance policies for terrorist financing into the Middle East, given American law enforcement agencies' increased focus on Palestinian terrorist organizations, compliance officers at banks in states where there have been remittances to and trade or charitable relationships with, the countries of the Middle East, are at a severe information disadvantage about who their targets should be, regarding the more obscure entities that exist, especially in Gaza and the West Bank. Why is there a dearth of publicly-available data about these smaller players, and their leaders?

As the press has repeatedly advised, not only are their other know terrorist organizations operating within Gaza, besides HAMAS and PALESTINIAN ISLAMIC JIHAD, but there are at least two other, more minor entities, and these entities are certainly targets, as they are said to be each holding Israeli and foreign hostages captured on October 7. Israeli media has accused Hamas of actually selling and trading hostages with these additional terrorist groups in Gaza. This means that American compliance officers must consider them to be already targeted and be under investigation by our law enforcement and intelligence agencies.

So why is there no public disclosure of the identities of these terrorist organizations, and of the names of their leaders? This puts compliance departments at a major disadvantage, as they do not know what or who to look for, when it comes to terrorist financiers. I understand the hesitation of US law enforcement agencies to disclose what it regards as sensitive information, and to not give them any publicity, but classifying or withholding this critical information will allow these smaller terrorist groups to obtain funding from their supporters abroad, especially from the United States. 

Therefore, we call for the release of not only the various names that these terrorist organizations operate under,and their fronts, but the identities of their leaders, and any other details that might allow compliance officers to spot terrorist financiers in the act of remitting funds. Make this information available please, so that compliance officers can protect their banks, and reduce the risk that they are unwittingly approving the funding of terrorist entities in Gaza. If necessary, declassify a sufficient amount of data so that we have the tools to do our job.