FIN-2023-Alert006: Hamas terrorist financing (virtual currency fundraising)
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FIN-2023-Alert006 October 20, 2023
FinCEN Alerts Financial Institutions to Hamas’s
Terrorist Financing
The Financial Crimes Enforcement Network (FinCEN) is
Suspicious Activity Report (SAR)
issuing this alert to assist financial institutions in identifying
Filing Request:
funding streams for the terrorist organization Hamas.1
FinCEN requests that financial
FinCEN is urging financial institutions to be vigilant in
institutions reference this alert in
identifying suspicious activity relating to financing Hamas
SAR field 2 (Filing Institution Note
and reporting such activity to FinCEN.
to FinCEN) and the narrative by
including the key term “FIN-2023- Hamas’s horrific terrorist attack on the people of Israel
TFHAMAS” and select SAR field on October 7, 2023, which left more than 1,000 innocent
33(a) (Terrorist Financing-Known civilians, including citizens of the United States and dozens
or suspected terrorist/terrorist
of other countries, wounded, killed, or taken hostage,2
organization.).
was funded by Hamas’s terrorist finance network and
practices. Hamas raises funds to support its operations
and members in a variety of ways, including through: support from Iran; a global portfolio of
investments; the control of border crossings and avenues of commerce; racketeering business
frameworks; extortionary practices around local populations; fundraising campaigns involving
virtual currency and fictitious charities raising both fiat and virtual currency, and diverting aid
and support from legitimate charities.3 Hamas moves funds through the smuggling of physical
currency as well as a regional network of complicit money transmitters, exchange houses, and
Hizballah-affiliated banks.4
1. The U.S. Department of State (State) designated Hamas as a foreign terrorist organization in October 1997. For an
overview of Hamas, see Office of the Director of National Intelligence (ODNI), Counter Terrorism Guide, “Hamas” (as
of Sept. 2022). State designated Hamas pursuant to Executive Order 13224 on October 12, 2001. See “Designations of
Terrorists and Terrorist Organizations Pursuant to Executive Order 13224 of September 23, 2001,” 67 FR 12633 (Mar.
19, 2002).
2. See White House, “Remarks by President Biden on the Terrorist Attacks in Israel” (Oct. 10, 2023), and “Statement
from President Joe Biden on American Citizens Impacted in Israel” (Oct. 9. 2023).
3. See U.S. Department of the Treasury (Treasury), “Remarks by Under Secretary for Terrorism and Financial Intelli-
gence Brian Nelson at Deloitte’s 15th Annual Anti-Money Laundering Conference” (Oct. 17, 2023). Iran provides
Hamas with funds, weapons, and training. During certain periods, Iran’s support to Hamas has been estimated to be
as high as $300 million per year, but at a baseline amount, is widely assessed to be in the tens of millions per year. See
FinCEN, “Imposition of Fifth Special Measure Against the Islamic Republic of Iran as a Jurisdiction of Primary Money
Laundering Concern,” 84 FR 59302 (Nov. 4, 2019); see also State, “Country Reports on Terrorism 2021: Iran” (2021).
4. See Treasury, “Treasury Targets Facilitators Moving Millions to HAMAS in Gaza” (Aug. 29, 2019). State designat-
ed Lebanese Hizballah as a foreign terrorist organization in October 1997. For an overview of Hizballah, see ODNI,
Counter Terrorism Guide, “Lebanese Hizballah” (as of Sept. 2022).
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F I N C E N A L E R T
Financial institutions, including virtual asset service providers (VASPs), should identify and report
suspicious transactions associated with Hamas’s financing as quickly as possible.5
As part of a whole-of-government response, the U.S. Department of the Treasury (Treasury) is
taking all necessary steps, including by issuing this Alert and engaging with foreign counterparts,
to deny Hamas the ability to raise and use funds worldwide.6 Building on previous actions against
Hamas, Treasury’s Office of Foreign Assets Control (OFAC) recently designated numerous Hamas
members, operatives, and financial facilitators located in Gaza and elsewhere, including Sudan,
Türkiye, Algeria, and Qatar.7
FinCEN has identified the following red flag indicators to help detect, prevent, and report
potential suspicious activity related to Hamas’s terrorist financing activity. As no single red flag
is determinative of illicit or suspicious activity, financial institutions should consider the totality
of available facts and circumstances, such as a customer’s historical financial activity, whether
the transactions are in line with prevailing business practices, and whether the customer exhibits
multiple red flags, before determining that a behavior or transaction is suspicious.
A customer or a customer’s counterparty conducts transactions with OFAC-designated entities
and individuals, or transactions that contain a nexus to identifiers listed for OFAC-designated
entities and individuals, to include, email addresses, physical addresses, phone numbers, or
passport numbers, or virtual currency addresses.
Information included in a transaction between customers indicates support for terrorist
campaigns.
A customer conducts transactions with a Money Services Business (MSB) or other financial
institution, including one that offers services in virtual currency, operates in higher-risk
jurisdictions tied to Hamas activity, and is reasonably believed or suspected to have lax
customer due diligence (CDD) requirements, opaque ownership, or otherwise fails to comply
with anti-money laundering/combatting the financing of terrorism (AML/CFT) best practices.
5. For cyber-related transactions, financial institutions should include any relevant technical cyber indicators related to
cyber events and associated transactions within the available structured cyber event indicator fields on the SAR form.
Any data or information that helps identify the activity as suspicious can be included as an indicator. Examples in-
clude chat logs, suspicious IP addresses, suspicious email addresses, and suspicious digital asset addresses. Financial
institutions are also encouraged to provide a citation to or clear explanation of the source of any external information
triggering the determination that the activity was suspicious or linked to Hamas.
6. See FinCEN, “READOUT: FinCEN holds meeting with Israel’s Financial Intelligence Unit” (Oct. 18, 2023).
7. See Treasury, Press Release, “Following Terrorist Attack on Israel, Treasury Sanctions Hamas Operatives and Fi-
nancial Facilitators | U.S. Department of the Treasury” (Oct. 18, 2023). To date, Treasury has targeted nearly 1,000
individuals and entities connected to terrorism and terrorist financing by the Iranian regime and its proxies, including
Hamas, Hizballah, and other Iran-aligned terrorist groups in the region. See also State, Press Statement by Antony
Blinken, U.S. Secretary of State, “Designating Hamas Operatives and Financial Facilitators - United States Department
of State” (Oct. 18, 2023).
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F I N C E N A L E R T
A customer conducts transactions that originate with, are directed to, or otherwise involve
entities that are shell corporations, general “trading companies,” or other companies that have
a nexus with Iran or other Iran-supported terrorist groups, such as Hizballah and Palestine
Islamic Jihad.8
A customer that is a charitable organization or nonprofit organization (NPO)9 solicits
donations but does not appear to provide any charitable services or openly supports Hamas’s
terrorist activity or operations. In some cases, these organizations may post on social media
platforms or encrypted messaging apps to solicit donations, including in virtual currency.
A customer that is a charitable organization or NPO receives large donations from an
unknown source over a short period of time and then sends significant wire transfers or
checks to other charitable organizations or NPOs.
A customer conducts transactions with known or suspected virtual currency addresses tied to
terrorism or terrorist financing donation campaigns.
FinCEN requests financial institutions reference this alert by including the key term “FIN-2023-
TFHAMAS” in SAR field 2 (Filing Institutions Note to FinCEN) and the narrative to indicate a
connection between the suspicious activity being reported and this alert.
The information contained in this alert is derived from FinCEN’s analysis of Bank Secrecy Act data,
open-source reporting, and information provided by law enforcement partners.
The mission of the Financial Crimes Enforcement Network is to safeguard
the financial system from illicit use, combat money laundering and its
related crimes including terrorism, and promote national security through
the strategic use of financial authorities and the collection, analysis, and
dissemination of financial intelligence.
8. State designated Palestine Islamic Jihad (PIJ) as a foreign terrorist organization in 1997. For an overview of PIJ, see
ODNI, Counter Terrorism Guide, “Palestine Islamic Jihad” (as of Sept. 2022).
9. FinCEN continues to emphasize that legitimate charities should have access to financial services and can transmit
funds through legitimate and transparent channels. As set out in the Joint Fact Sheet on BSA Due Diligence Re-
quirements for Charities and Non-Profit Organizations, banks are reminded to apply a risk-based approach to CDD
requirements when developing the risk profiles of charities and other non-profit customers. The application of a risk-
based approach is consistent with existing CDD and other Bank Secrecy Act/ AML compliance requirements. FinCEN,
Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation, National Credit Union
Administration, and Office of the Comptroller of the Currency, “Joint Fact Sheet on Bank Secrecy Act Due Diligence
Requirements for Charities and Non-Profit Organizations” (Nov. 19, 2020).
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