The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced that it has imposed sanctions on ten Hamas members, operatives, and financial facilitators, including a Gaza-based money services business (MSB), Buy Cash Money and Money Transfer Company. Buy Cash has been used to transfer funds by affiliates of terrorist groups, including Hamas, al-Qaeda and the Islamic State (ISIS), in addition to facilitating cryptocurrency fundraising efforts for Hamas.
Today’s action by OFAC aims to disrupt Hamas’ revenue sources in the West Bank, Gaza, and elsewhere. In addition to Buy Cash, those sanctioned include individuals involved in a secret Hamas investment portfolio and an operative with deep ties to the Iranian regime and its proxies.
Notable individuals and entities sanctioned
- Musa Muhammad Salim Dudin: A West Bank-based member of Hamas’ Political Bureau, involved in negotiations for imprisoned Hamas members and linked to weapon purchases
- Abdelbasit Hamza Elhassan Mohamed Khair: A Sudan-based Hamas financier, associated with various companies and financial transfers for Hamas
- Amer Kamal Sharif Alshawa, Ahmed Sadu Jahleb, Aiman Ahmad Al-Duwaik, and Walid Mohammed Mustafa Jadallah: Involved in Hamas’ investment network
- Muhammad Ahmad ‘Abd Al-Dayim Nasrallah: A Qatar-based Hamas operative with close Iranian ties, involved in major financial transfers to Hamas
- Ayman Nofal: Hamas military member, reportedly killed in a recent airstrike
- Buy Cash Money and Money Transfer Company: Gaza-based business linked to Hamas’ cryptocurrency fundraising efforts
- Ahmed M. M. Alaqad: Gaza-based owner and representative of Buy Cash
The recent sanctions extend OFAC’s previous actions against Hamas’ covert international investments, which generate massive amounts of revenue for the organization. These investments, potentially worth hundreds of millions of dollars, operate under the guise of legitimate businesses across various countries. The individuals and entities sanctioned today are based in Gaza and elsewhere including Sudan, Turkey, Algeria, and Qatar.
Hamas, Palestinian Islamic Jihad (PIJ), and the Popular Front for the Liberation of Palestine (PFLP) have been recognized as Foreign Terrorist Organizations (FTOs) by the United States since 1997, and as Specially Designated Global Terrorists (SDGTs) since October 2001.
Tracing Buy Cash’s on-chain activity
Chainalysis has been aware of Buy Cash and its role in terrorism financing for a few years. For instance, in our August 2020 blog post on a United States-led disruption of a terrorism financing ring, we referred to Buy Cash as a Gaza-based MSB and showed some of its on-chain activity. In a July 2021 post on Israel’s seizure of cryptocurrency associated with Hamas donation campaigns, we referred to Buy Cash as a Middle East-based MSB and showed similar on-chain activity. OFAC’s action today means this information is now publicly available.
Operational between April 2014 to November 2022, Buy Cash has received millions of dollars in total transfers. As we highlight in the graph below, and according to today’s designation, Buy Cash has received funds on-chain from Hamas Al-Qassam Brigades fundraisers both directly, and through intermediaries. It has also received funds from Ibn Taymiyyah Media Center (ITMC), which is the media wing of Mujahideen Shura Council (MSC) in the Environs of Jerusalem, a jihadist group based in Gaza and designated as a Foreign Terrorist Organization by OFAC since August of 2014. We can see this activity on the Chainalysis Reactor graph below (flows to and from Buy Cash are highlighted in red).
Are you a Reactor user? Click here to see this graph for yourself.
Hamas often utilizes small-dollar cryptocurrency donations to fund its activities. In June 2021, Israel’s National Bureau for Counter Terror Financing of Israel (NBCTF) seized cryptocurrency wallets linked to a Hamas fundraising campaign. As we noted in 2021, one of these wallets belonged to Buy Cash. Furthermore, one of the seized wallets fundraising for Hamas also sent funds to Buy Cash.
Buy Cash, while implicated in Hamas crypto activity, also facilitated transfers for other terrorist groups — notably, a 2019 bitcoin transfer from an al-Qaeda affiliate and a 2017 procurement of online infrastructure on behalf of ISIS. Additionally, the Gaza-based owner and representative of Buy Cash, Ahmed M. M. Alaqad, is now designated under E.O. 13224 for his support of Hamas.
Today’s designation of Buy Cash included one Bitcoin address as an identifier: 19D1iGzDr7FyAdiy3ZZdxMd6ttHj1kj6WW. This address, along with other Buy Cash addresses identified by Chainalysis, has been labeled as sanctions-related in all of our products.
The importance of blockchain analysis in disrupting terrorism networks
Today’s sanctions by OFAC highlight the critical role of blockchain analysis in targeting and disrupting terrorist financing networks. A united effort between global law enforcement and the broader cryptocurrency industry is paramount to disassemble current terrorism financing avenues and prevent the establishment of new ones.
Chainalysis stands firm in its commitment to equip government bodies, global law enforcement agencies, and businesses with state-of-the-art blockchain analysis tools to combat nefarious activities on-chain.
This material is for informational purposes only, and is not intended to provide legal, tax, financial, or investment advice. Recipients should consult their own advisors before making these types of decisions. Chainalysis does not guarantee or warrant the accuracy, completeness, timeliness, suitability or validity of the information in this report and will not be responsible for any claim attributable to errors, omissions, or other inaccuracies of any part of such material.