RegAlert2023-10-20 | FIN-2023-Alert006Added · Updated
FinCEN Alert to Financial Institutions to Counter Financing to Hamas and its Terrorist Activities (FIN-2023-Alert006)
FinCEN requests that financial institutions reference alert FIN-2023-Alert006 in Suspicious Activity Report (SAR) field 2 and the narrative by including the key term "FIN-2023-TFHAMAS" and selecting SAR field 33(a) for terrorist financing. The alert provides red flag indicators to help detect suspicious transactions associated with Hamas, such as dealings with OFAC-designated entities, shell corporations with Iran nexus, or charitable organizations soliciting donations without providing services. Financial institutions, including virtual asset service providers, are urged to identify and report suspicious activity related to Hamas's financing network as quickly as possible.
FINCEN published 7 documents in the last 30 days — get each new one by email the day it lands.
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- 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). - 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). - See U.S. Department of the Treasury (Treasury), “Remarks by Under Secretary for Terrorism and Financial Intelligence 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). - See Treasury, “Treasury Targets Facilitators Moving Millions to HAMAS in Gaza” (Aug. 29, 2019). State designated 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).
FIN-2023-Alert006 October 20, 2023
FinCEN Alerts Financial Institutions to Hamas’s Terrorist Financing The Financial Crimes Enforcement Network (FinCEN) is issuing this alert to assist financial institutions in identifying funding streams for the terrorist organization Hamas.1
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Lineage: In force
Source: Financial Crimes Enforcement Network — original document · Summary generated with machine assistance and reviewed before publication; the authoritative text is the regulator's original document. How RegAlert works