OFAC designations of a Hamas financing network: no digital currency addresses listed
Summary
On 2 October 2026, the US Treasury’s Office of Foreign Assets Control (OFAC) designated three individuals and two France-based registered charities under Executive Order (E.O.) 13224, as amended by E.O. 13886, which Treasury describes as “the United States’ core counterterrorism sanctions authority”. Treasury states that the designations expose a financing architecture that moved “more than $2 million to Hamas through deceptive charitable fronts and cryptocurrency channels”.
Between them, the five entries added to OFAC’s Specially Designated Nationals (SDN) List include names, aliases, dates of birth, addresses, and identity or registration numbers. When checked on 3 October 2026, none of the five entries listed a digital currency address.
What was announced
According to the Treasury press release, OFAC “designated a member of Hamas’s military wing, along with two France-based individuals and two affiliated entities that provide critical financing to Hamas”. The release states that the action “aligns with a broad, multi-jurisdictional operation led by the Federal Bureau of Investigation (FBI) to dismantle several Hamas fundraising ventures, including those active inside the United States”.
The release also notes that the US Department of State designated Hamas under E.O. 13224 on 31 October 2001, and that Hamas is designated as a Foreign Terrorist Organization under section 219 of the Immigration and Nationality Act.
Persons designated
The release gives the following descriptions and legal bases:
Saleem Abdallah Saleem al-Zaq, described as “a Gaza-based battalion deputy in the Hamas military wing”, designated “for having acted or purported to act for or on behalf of, directly or indirectly, Hamas”;
Faouzi Barika, who operates from France, designated “for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, Hamas”;
Amel Oualid, who operates from France, designated on the same basis in relation to al-Zaq rather than Hamas;
Association Baraka, a France-based association registered as a charity, which the release states Barika established jointly with al-Zaq; and
Ensemble C Mieux, a France-based association registered as a charity, which the release states Oualid established.
The release designates the two associations are designated “for being owned, controlled, or directed by, directly or indirectly, Barika and Oualid, respectively”. The release describes them as “purported charities” run “ostensibly to raise money for humanitarian purposes to aid Gazan civilians”.
Use of cryptocurrency
The release states that al-Zaq “oversees a financial network that has used various money services businesses and cryptocurrency wallets to transfer significant funds to the Hamas Al-Qassam Brigades”.
It also states: “During a six-year period from 2020–2026, Barika, Oualid, and al-Zaq collected more than $2 million for Hamas, of which $1.5 million was collected after the October 7, 2023 Hamas attack on Israel.” It adds that “Barika and Oualid sent hundreds of thousands of dollars in cryptocurrency to al-Zaq”, and that al-Zaq advertised their fundraising accounts on his own social media accounts.
Identifiers in the SDN entries
The SDN entries published on OFAC’s Recent Actions page for 2 October 2026 include:
names and, for three entries, aliases: ALZAQ, Saleem A.S.; ZAK, Salim; BOUCHEKIF, Amel; and, for Ensemble C Mieux, “TOGETHER IT'S BETTER”;
for the individuals, dates of birth, nationality, gender and addresses, and places of birth for Barika and Oualid;
passport numbers (al-Zaq, Barika), a national identity number (al-Zaq) and driving licence numbers (Barika, Oualid);
for the two associations, French charity registration numbers, establishment dates (13 October 2023 for Association Baraka and 1 July 2024 for Ensemble C Mieux) and the target type “Charity or Nonprofit Organization”, with a website and email address for Association Baraka;
the programme tag [SDGT] and a “Linked To” field on each entry; and
on each entry, “Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886”.
No entry lists a digital currency address.
Sanctions implications set out by Treasury
The release states the following.
Property and interests in property of the designated persons “that are in the United States or in the possession or control of U.S. persons are blocked and must be reported to OFAC”. Entities owned 50 per cent or more, directly or indirectly, individually or in the aggregate, by one or more blocked persons are also blocked.
“Unless authorized by a general or specific license issued by OFAC, or exempt, OFAC’s regulations generally prohibit all transactions by U.S. persons or within (or transiting) the United States that involve any property or interests in property of blocked persons.”
“Violations of U.S. sanctions may result in the imposition of civil or criminal penalties on U.S. and foreign persons.”
“OFAC may impose civil penalties for sanctions violations on a strict liability basis.”
“Non-U.S. persons are also prohibited from causing or conspiring to cause U.S. persons to wittingly or unwittingly violate U.S. sanctions, as well as engaging in conduct that evades U.S. sanctions.”
Engaging in certain transactions involving the designated persons “may risk the imposition of secondary sanctions on participating foreign financial institutions”. OFAC can prohibit or impose strict conditions on the opening or maintaining, in the United States, of a correspondent or payable-through account of a foreign financial institution that knowingly conducts or facilitates any significant transaction on behalf of a person designated under the relevant authority.
Implications for CASPs
The following points are our assessment rather than statements by Treasury or OFAC.
Screening. A crypto-asset service provider (CASP) that screens wallet addresses against the SDN List will find no match for these persons, because no addresses are listed. Without listed addresses, identification relies on screening names, aliases and the other listed identifiers against customer and counterparty data, including Travel Rule information, alongside transaction monitoring. Blockchain analytics providers may independently attribute addresses to this network independently; such attribution is vendor information, not an OFAC listing.
Look-back. Treasury cites activity from 2020 to 2026, a period that begins before the associations’ establishment dates. A CASP considering a retrospective review should note that its record coverage for that period may vary by firm and jurisdiction.
Non-US CASPs. As set out above, the release states that OFAC’s regulations generally prohibit transactions by US persons, or within or transiting the United States, that involve blocked property, and that non-US persons are prohibited from causing US persons to violate US sanctions or from evading them. It also states that foreign financial institutions engaging in certain transactions involving these persons may risk secondary sanctions, including restrictions on US correspondent and payable-through accounts. Whether a particular CASP is a “foreign financial institution” for these purposes is a legal question that the release does not address.
Payment flows. Treasury describes public donations solicited through purported charities and fundraising accounts advertised on social media. Flows of many small inbound transfers, and transfers to or from self-hosted wallets, are where originator or beneficiary names may be incomplete.
Other regimes. This note does not address whether the persons are subject to EU, UK or French asset-freeze measures.
Timeline
31 October 2001. The US Department of State designates Hamas under E.O. 13224.
2 October 2026. OFAC designates five persons under E.O. 13224, as amended; Treasury press release sb0647.
Sources
James Ross, Head of Advisory, denouement. This note is for information only and is not legal advice.
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