On November 14, 2023, OFAC released its Guidance for the Provision of Humanitarian Assistance to the Palestinian People to “clarify that U.S. sanctions do not stand in the way of legitimate humanitarian assistance to the Palestinian people.” The Guidance reinforces existing prohibitions and authorizations, along with a brief review of applicable general licenses and Q&A.
Hamas and other organizations have used NGOs to support financing of their operations, making due diligence on suspect transactions and entities critically important in the sanctions space. In addition, The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has imposed several rounds of sanctions targeting Hamas-affiliated individuals and entities and does not maintain any jurisdiction based sanctions on Gaza or the West Bank.
Your institution may have customers who wish to support humanitarian efforts to those impacted in the area, and OFAC encourages donors to identify trusted organizations should individuals wish to contribute. To determine validity, you may want to check SDN list, review the red flags issued in the FinCEN Alert to Financial Institutions to Counter Financing to Hamas and its Terrorist Activities, and understand where and how funds may be used.
If you’re interested in learning more about OFAC through the lens of current world events, join us and Lori Moore on December 20, 2023 for the session A World in Chaos: The Importance of a Strong OFAC Program. It’s a deep dive into OFAC compliance and you’ll come away understanding how to maintain an effective system of controls, ensure compliance, and a strong line of defense.
As always, we’re here to help and if you have any questions about OFAC Compliance, you can drop us a line.