FinCEN issues guidance for identifying Hamas funding

The Financial Crimes Enforcement Network today issued an alert to help financial institutions identify funding streams for the terrorist organization Hamas. The guidance was released in response to Hamas’ Oct. 7 attack on Israel, which killed more than 1,000 people. In a statement on X, the American Bankers Association thanked the agency for responding to banker concerns on this issue.

The alert lists several red flags to help detect potential suspicious activity related to Hamas’ financing activity. They include transactions with companies that have a nexus of support with Iran, which financially supports Hamas; nonprofits that solicit donations but do not appear to provide any charitable services or openly support Hamas’ terrorist activity; and transactions with known or suspected virtual currency addresses tied to terrorism or terrorist financing donation campaigns.

“As no single red flag is determinative of illicit or suspicious activity, financial institutions should consider the totality of available facts and circumstances, such as a customer’s historical financial activity, whether the transactions are in line with prevailing business practices, and whether the customer exhibits multiple red flags, before determining that a behavior or transaction is suspicious,” FinCEN said.