AMERICAN BANKERS: IS YOUR NEW CANADIAN CLIENT A HAMAS LEADER ENGAGED IN TERRORIST FINANCING?

Canadian media are reporting that an estimated 450 Hamas terrorists now hold Canadian passports, and since Canadian citizens generally do not need a visa for most temporary visits to the U.S.and can enter with a valid Canadian passport for up to six months for tourism or business, there is a definite risk that your new affluent Canadian "businessman" opening an account is bent on using your bank to facilitate terrorist financing, masquerading as import/export.

The dual Canadian-Lebanese national, Usama Ali, who has reportedly sat on Hamas’s powerful Shura Council since 2019, is sanctioned by the U.S. Treasury and is reported to also head Hamas’s Turkey-based Investment Office, managing at least $500 million in assets through significant real estate sales and major construction companies.In addition to posing as Lebanese, Hamas agents have obtained Canadian passports in the past by claiming to be Syrians fleeing that country's civil war. compliance officers must therefore, seek to identify the passport holder's place of birth, to determine whether he or she is possibly a Palestinian, which should trigger an enhanced due diligence investigation, prior to account opening, to rule out terrorist links. This is suggested for risk management, and does not constitute discriminatory action when it is conducted for CTF reasons. If you have any reservations, you should confirm this policy with your bank's legal counsel.

You do not want to onboard any new Canadian client who takes advantage of Canadian banks' poor record on interdicting terrorist financing to allow fellow Hamas operatives to move their funding through a US financial institutions.