Treasury Sanctioned a Hamas Crowdfunding Network. Its French Front Should Be Next.

U.S. and French authorities have moved against a Hamas fundraising network that allegedly raised more than $600,000 from American donors. The harder task is keeping it from rebuilding. On October 2, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) designated Saleem Abdallah Saleem al-Zaq, a Gaza-based battalion deputy in Hamas’s military wing, along with France-based Faouzi Barika and Amel Oualid. OFAC also sanctioned the two French associations they established, Association Baraka and Ensemble C Mieux. Treasury noted that the three collected more than $2 million for Hamas, $1.5 million of which was raised in the wake of Hamas’s October 7, 2023, mass atrocities in Israel. The Justice Department also announced material support for terrorism charges against al-Zaq and three U.S. residents. The Network’s Reach on U.S. Soil According to the indictment, al-Zaq’s crowdfunding campaigns claimed to provide food and winter necessities to Gazans, raising around $1.75 million, including approximately $626,000 from U.S.-based donors. Prosecutors say al-Zaq in fact used money from the campaigns to support Hamas, and Treasury says his network moved significant funds to Hamas’s military wing through money services businesses and cryptocurrency wallets. The indictment also alleges that in October 2024, al-Zaq told donors not to write “free Palestine” or “long live Hamas” on donations to his PayPal accounts so the accounts would not be shut down. On October 20, 2023, less than two weeks after Hamas’s attack on Israel, the Treasury Department’s Financial Crimes Enforcement Network (FinCEN) issued an alert to help financial institutions identify and report suspicious transactions tied to Hamas financing. One of the red flags it lists is transaction information between customers that indicates support for terrorist campaigns — the kind of payment notes al-Zaq allegedly told donors to avoid. What the Designations Cannot Reach The designations block the targets’ property in the United States or in the possession or control of U.S. persons, such as U.S. banks, and generally prohibit U.S. persons from dealing with the targets. But they leave two gaps: they cannot compel French banks to freeze euro-denominated accounts, and they do not identify the network’s cryptocurrency wallets. French prosecutors have charged Barika and Oualid with financing Hamas, which they dispute. Neither of the designated associations appears in France’s national asset-freeze register, though their funds may already be restricted through the criminal proceedings. Three days after the designations, Association Baraka’s website was still asking donors to give through PayPal and to contact “our brother” in Gaza on Snapchat and WhatsApp. Additionally, OFAC’s sanctions entries list no digital currency addresses for the network. That omission may make it harder for exchanges and other institutions to identify and block the network’s crypto holdings. Enforcing the Sanctions The U.S. indictment describes a network built to adapt, allegedly rotating payment recipients to avoid scrutiny, switching crypto exchanges after one questioned its funds, and registering a French association the day after a crowdfunding campaign closed. Washington should build on the joint operation by working with Paris to ensure the associations’ funds are frozen or seized, and Association Baraka and Ensemble C Mieux are dissolved and added to the EU terrorist list. France has been slow to act against Hamas fronts before. In 2003, Treasury designated the French charity CBSP as a Hamas fundraiser, yet French authorities seized funds from its successor, Humani’Terre, and froze its assets only in 2024, before charging five people linked to it in February 2026. Treasury has repeatedly targeted Hamas’s sham charities. The challenge is keeping such fronts from returning under new names. OFAC should also add the network’s digital currency addresses to its sanctions entries, closing the kind of enforcement gap Hamas has exploited in its use of cryptocurrency. Blockchain analytics firm Chainalysis has reported that an address al-Zaq controlled is a deposit address at a global exchange; publishing it would put that exchange on notice. PayPal, a U.S. person, is generally barred from providing services to designated parties and should close any accounts tied to them. Additionally, insofar as the designated parties’ use of messaging services such as Snapchat and Meta’s WhatsApp may be exempt from sanctions prohibitions under the statutory informational materials exemption, the companies should assess whether the parties’ conduct in support of Hamas violates their terms of service. Ryan Wohl is a research associate at the Foundation for Defense of Democracies (FDD). For more analysis from Ryan and FDD, please subscribe HERE. Follow FDD on X @FDD. FDD is a Washington, DC-based, nonpartisan research institute focusing on national security and foreign policy.