On January 21, 2026, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) took decisive action to expose and disrupt a network of organizations covertly supporting the militant activities of Hamas. In the press release identified as SB0368, Treasury outlined an expanded enforcement strategy designed to both protect humanitarian channels and tighten oversight of entities that exploit the financial system under the guise of charitable work.
This action is a significant update in how OFAC applies and communicates its economic sanctions guidelines. Although not a formal amendment to the regulatory text, the announcement serves as a practical update to sanctioned-entity identification, enforcement posture, and risk communication. It also reinforces how the OFAC Economic Sanctions Enforcement Guidelines are applied in context.
OFAC operates under long-standing national security and counterterrorism authorities, including Executive Order 13224, which allows the U.S. to designate individuals and entities that materially assist terrorist organizations. Hamas has been designated under this authority since 2001 and is recognized as a Foreign Terrorist Organization under U.S. law.
The Treasury press release makes clear that the latest actions were taken under this same statutory authority, but with renewed emphasis on transparency to prevent exploitation of humanitarian channels.
Key Updates in Guidance and Sanctions Application
Although SB0368 focuses on sanctions actions, it effectively updates several practical aspects of how OFAC guidance is implemented on the ground. These updates can be grouped into the following themes:
1. Expanded Targeting of Covert Networks
The Treasury identified six Gaza-based organizations that claim to provide medical and humanitarian services but are in fact substantively controlled by Hamas’s military wing, the Izz al-Din al-Qassam Brigades. Each of these organizations is now designated for sanctions purposes.
These entities are:
- Waed Society Gaza
- Al-Nur Society Gaza
- Qawafil Society Gaza
- Al-Falah Society Gaza
- Merciful Hands Gaza
- Al-Salameh Society Gaza
What makes this particularly noteworthy is the breadth of support activities these organizations provided to Hamas, including:
- Handling internal Hamas funding flows,
- Directing resources to military wing members,
- Serving as front groups to channel donor funds into operational support.
By publicly identifying these entities as part of Hamas’s network, Treasury is signalling that organizations claiming to be charitable but controlled by militant groups will be scrutinized and, where appropriate, designated.
2. Clarification of Front Organization Risks
The designation of the Popular Conference for Palestinians Abroad (PCPA) and at least one individual associated with the group, Zaher Khaled Hassan Birawi, serves as a wake-up call about front organizations that are purposefully structured to obscure their true affiliations.
According to Treasury, the PCPA was used as a vehicle for Hamas to project influence and fundraise under the cover of representing Palestinian diaspora interests. This underscores a key evolution in OFAC policy: front organizations are now actively being targeted not only for funding terrorist groups but also for engagement in political or advocacy efforts that mask their operational ties to violence.
This update in enforcement practice highlights that organizations, even those engaged in legitimate cultural or community work can be subject to sanctions if they are owned, directed, or controlled by proscribed groups.
3. Reinforcing OFAC’s Risk Communication Strategy
Perhaps the most significant update in practical terms is the way OFAC is communicating risk to both humanitarian actors and the broader public. By publicly exposing these Hamas-linked groups, Treasury is sending a clearer message that:
- Donors must perform enhanced due diligence,
- Charitable contributions to organizations operating in conflict zones carry sanctions risk,
- Failure to recognize and avoid funds flowing through deceptive channels can lead to sanctions violations.
This represents an informal but meaningful extension of the Economic Sanctions Enforcement Guidelines and clarifies how entities should evaluate their compliance posture.
4. Reinforcing Broad Sanctions Implications
With the designations now in place, Treasury reminded stakeholders about the real consequences of dealing with sanctioned parties:
- Blocking of all property and interests of designated persons,
- Prohibition of most transactions involving U.S. persons or those occurring in the United States,
- Potential penalties for non-profits, financial institutions, and individuals who facilitate prohibited transactions,
- Risk of secondary sanctions on foreign financial institutions that knowingly assist in evading sanctions.
This portion of the guidance is not new in text, but its emphasis in this context is notable. Treasury is reasserting that sanctions enforcement remains strict and broad in scope, including for entities that may be several layers removed from core proscribed activities.
5. Whistle-blower Incentives and Reporting Channels
Another practical enhancement stressed in the press release relates to Treasury’s encouragement of reporting sanctions violations. The Financial Crimes Enforcement Network (FinCEN), a part of Treasury, currently accepts whistle-blower tips, with potential monetary awards for information that leads to successful enforcement actions.
This reiterates and strengthens guidance within the Enforcement Guidelines regarding encouraging voluntary reporting of suspicious activity, particularly as it intersects with international terrorism financing.
Broader Implications for Humanitarian Aid and Donor Confidence
A central concern addressed in the Treasury update is the effect of sanctions on legitimate humanitarian flows to the Palestinian people. Treasury reiterated that protecting legitimate humanitarian aid remains a priority and that these designations aim to make it easier, not harder, for genuine aid to reach those in need.
This includes ongoing availability of humanitarian general licenses, which allow certain categories of assistance to proceed despite the sanctions regime, provided they meet strict criteria.
What has changed in guidance here is greater clarity around which types of organizations are not to be trusted implicitly, and how donors must be more vigilant. By naming specific entities and providing underlying evidence of their connections to Hamas, Treasury aims to reduce overall terrorist financing risk in the sector.
Conclusion: A Strategic Enforcement Update
Although the SB0368 press release does not revise the regulatory text of U.S. sanctions law, it operationalizes significant updates in how the U.S. Treasury applies and communicates sanctions policy in conflict zones and complex organizational environments.
Key developments include:
- A broader and clearer targeting of front organizations that disguise military financing under humanitarian pretexts,
- Improved risk communication to donors, NGOs, and financial institutions,
- Reemphasis on sanctions consequences, including secondary sanctions,
- Support for whistle-blower reporting to enhance enforcement,
- Assurance of pathways for legitimate humanitarian aid.
These actions collectively reinforce OFAC’s focus on disrupting terrorist financing while ensuring the integrity of lawful aid channels. By publicly naming misused organizations and contextualizing the risks, Treasury has updated not just whom it sanctions, but how it expects global actors to interpret and comply with the sanctions ecosystem.
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