FRONTLINE COMPLIANCE OFFICERS SHOULD BE ALERT FOR NEW SOURCES FUNDING HAMAS, DUE TO EITHER IGNORANCE OR DESIGN

Austin, Texas

The explosion of so-called "Pro-Palestinian" protest, some of which is thinly-disguised antisemitism by obvious pro-Hamas elements, either with or without covert support from agents working for Russia, China and/or Iran, means that compliance can expect some of these individuals, or NGOs, to seek to send funds that constitute terrorist financing of Hamas. They may be what are known as "useful idiots," contributors acting in good faith, who are unaware that they are  financing a global terrorist organization, or they may be intentionally supporting that SDGT. Either way, they are terrorist financiers, at a time when one can expect strict law enforcement and regulatory action from American agencies, due to the fact that our governments is supporting Israel as  part of its national counter-terrorism policy.

Therefore, frontline compliance officers must be on alert for any suspicious activity, including unusual and new remittances to Middle eastern NGOs and charitable organizations, or international trade payments that appear to be new contracts, as well as large payments for university attendance which never has appeared before. Do not underestimate these new Hamas supporters. It is their new appearance on the scene which may give them away. Do you have any bank clients who, since October 7, are sending major wire transfers to the Middle East, especially Turkey, where Hamas has a substantial physical presence?

New York City

Remember, terrorist financiers are constantly seeking new opportunities to fund their organization, whether that be through ignorance or neglect of remitters who believe they are providing support for victims, or in concert with new supporters, who match their legal First Amendment rhetoric with unlawful actions; Watch for it.