OFAC Hamas Sanctions

The Office of Foreign Assets Control (OFAC), part of the U.S. Department of the Treasury, administers sanctions targeting Hamas under several overlapping authorities. The core legal basis is Executive Order 13224 (signed by President George W. Bush on September 23, 2001), which authorizes blocking the property of persons who commit, threaten, or support acts of terrorism. Hamas was designated a Specially Designated Global Terrorist (SDGT) under E.O. 13224 and had been previously designated a Foreign Terrorist Organization (FTO) by the U.S. State Department in 1997 under section 219 of the Immigration and Nationality Act.

Practically, OFAC's Hamas-related designations appear on the Specially Designated Nationals and Blocked Persons (SDN) List. The consequences include:

• Freezing of all property and interests in property within U.S. jurisdiction.
• A prohibition on U.S. persons engaging in any transactions with listed individuals or entities.
• Secondary exposure for non-U.S. banks that process related dollar transactions, which can trigger correspondent-account restrictions.

Following the October 7, 2023 Hamas attacks on Israel, OFAC issued a series of designation rounds in coordination with the United Kingdom and other partners, targeting Hamas investment portfolio managers, Gaza-based financial facilitators, members of the al-Qassam Brigades, and money service businesses in Gaza and the broader region. Subsequent rounds in 2024 added cryptocurrency wallets and donors routing funds through third countries.

OFAC enforcement is paired with criminal authorities under 18 U.S.C. § 2339B (material support to designated FTOs). Penalties for violations can include civil fines, criminal prosecution, and reputational listing. OFAC periodically issues general licenses permitting limited humanitarian activity in Gaza, though these are narrow and do not authorize transactions with Hamas itself. The program is distinct from, but often coordinated with, EU and UK Hamas-related listings.