The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) has sanctioned three individuals and two sham charities for operating a financing network that funneled more than $2 million to Hamas using digital assets and charitable fronts. Simultaneously, the Department of Justice (DOJ) unsealed criminal charges against Saleem al-Zaq and announced six arrests linked to the network.
Key Takeaways:
- OFAC sanctioned Saleem al-Zaq, Faouzi Barika, Amel Oualid, and two French organizations: Association Baraka and Ensemble C Mieux.
- The illicit network funneled over $2 million to Hamas, including $1.75 million raised through December 2025, with at least $626,000 coming from U.S. donors.
- The network transitioned from Western Union to Bitcoin in December 2021 to conceal funds bound for the Al-Qassam Brigades.
Structure of the $2 Million Terrorist Financing Operation
According to U.S. prosecutors and Treasury releases, the fundraising architecture operated through Association Baraka and Ensemble C Mieux, two France-based entities managed by Faouzi Barika and Amel Oualid. The charities collected funds from donors under the premise of providing humanitarian aid to civilians in Gaza. Blockchain intelligence firm Chainalysis noted that donations were initially pooled inside a French bank account before being converted into cryptocurrencies.
In December 2021, Saleem al-Zaq, identified as a Gaza-based battalion deputy in Hamas's Al-Qassam Brigades, instructed his France-based partners to switch from Western Union wire transfers to Bitcoin and other digital currencies. Treasury detailed that Barika and Oualid subsequently transferred hundreds of thousands of dollars in digital assets directly to al-Zaq. When a crypto exchange questioned the origin of funds in May 2023, the partners shifted operations to a different platform. Chainalysis eventually linked al-Zaq's deposit addresses to counterparties tied to Hamas-linked wallets previously targeted in Israeli seizure orders. Investigations like this align with broader efforts by Chainalysis tracking illicit crypto movements across international borders.
Enforcement Escalation and Previous Countermeasures
This action builds on prior sanctions by OFAC, which targeted the Gaza-based cryptocurrency exchange Buy Cash in October 2023. Although OFAC's latest release did not specify individual wallet addresses, federal authorities confirmed that the broader infrastructure moved more than $2 million to Hamas through evasive channels. This regulatory action coincides with global efforts enforcing strict compliance standards, such as ESMA custody rules targeting non-compliant crypto services.
Why It Matters
This enforcement action highlights how sanctioned entities adapt their fundraising tactics by combining legacy banking systems, fake non-profit entities, and digital assets to bypass global banking oversight. Although cryptocurrency was chosen to obscure payment trails, the transparent nature of public blockchains allowed forensic analysts to trace cross-border transfers back to previously seized wallets. As federal scrutiny intensifies, cryptocurrency exchanges face heightened pressure to implement rigorous counterparty monitoring and flag rapid platform migrations designed to evade detection.
