WHO CAN WE TRUST TO PERFORM EFFECTIVE COMPLIANCE IN GAZA'S BANKS WHEN THE SHOOTING STOPS? WILL IT BE UP TO EXPATS AND OTHERS BROUGHT IN FROM THE GULF STATES?

While there has been much said about how post-war Gaza should, and must be, governed during the years it will take to rebuild housing, infrastructure, a working economy, and hopefully a representative democracy, nobody in the financial sector is talking about the issues surrounding AML compliance there, when the banks and non-bank financial institutions reopen after the dust settles.

These points must be recognized, in order that there be effective AML/CFT
in the Palestinian Territories after the present war ends:

(1) There are literally billions of dollars worth of Israeli Shekels in circulation in Gaza, as well as US Dollars.

(2) Much of this currency is presently in the hands of designated terrorist organizations, their leaders, and their agents.

(3) It is expected that a significant portion of that cash will remain hidden inside Gaza in the future, and that individuals whose affiliation with terrorist organizations is not known will attempt to launder a portion of it during the future peacetime period by depositing it into reopened Palestinian banks and NBFIs.

(4) Unless those funds are identified, seized and forfeited, they could constitute terrorist financing for future operations in the Territories. This assumes that there will be relevant regulations in place authorizing these acts.

Therefore, planning for importing trained and experienced compliance officers from outside Gaza should be a part of any post-war agenda, lest history be allowed to repeat itself, and yet another war plague the region.