ARE YOU PERHAPS ACCEPTING USD DEPOSITS THAT MIGHT HAVE COME FROM A BANK ROBBERY?

Buried in the after-action reports from the ongoing war in Gaza is the information that Hamas, in order to have the necessary Israeli currency it needs to pay the surviving terrorists who are still fighting, has broken into the country's commercial banks, opened their safes, and taken out all the cash. Since their people can only use Shekels inside Gaza, the caches of valuable US Dollars they steal will most likely end up in the hands of senior Hamas officials, many of whom have grown rich, due to opportunities they have had in the past to divert aid payments, UNRWA salaries, which are paid in Dollars, and many other corrupt means of securing hard currency for their future.

When the war comes to an end, it must be assumed that much of those greenback holdings will find their way into an EU bank or two, in the hands of individuals, conveniently holding valid Jordanian passports. Have your Arabic-speaking staff interview them at length, to determine whether their spoken language, including slang, marks them as Palestinians. If they are, then enhanced due diligence is in order, to rule out that they were inside Gaza during the war, and may be involved in terrorist financing, or terrorism itself.

The individuals will have a large amount of US currency, ignore any new bank clients with small quantities of cash; you are looking for these with large bankrolls that they wish to deposit, and therefore begin a journey of laundering that money through your bank. Are they fifty and one hundred dollar notes, and do they appear to be in good physical condition? if so, they may have very well come from a Palestinian bank's safe, taken straight out of a stack of bills held in storage, but which are the proceeds of a bank heist.

If you are a compliance officer at an EU bank with substantial international clientele from the Middle East, you will want to start closely examining anyone that fits my description, starting immediately after a Cease-Fire is announced,