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 […]
