OFAC sanctioned two French charities and three individuals on October 2, alleging they helped channel cryptocurrency and other funds to Hamas. Treasury says the network raised more than $2 million for the group between 2020 and 2026, with hundreds of thousands specifically sent in crypto by two France-based fundraisers.
The designations hit Association Baraka, Ensemble C Mieux, Faouzi Barika, Amel Oualid, and Saleem Abdallah Saleem al-Zaq. Treasury described al-Zaq as a Gaza-based deputy battalion commander in Hamas' military wing.
The crypto transactions Treasury actually flagged
Barika and Oualid, both based in France, are accused of sending hundreds of thousands of dollars in cryptocurrency to al-Zaq. That figure covers the digital-asset transfers specifically attributed to the two men. It doesn't cover the broader $2 million fundraising total, which Treasury says included other funds and wasn't all crypto. The distinction matters for compliance teams trying to scope exposure — the crypto piece is narrower than the headline number.
What US firms have to block
The sanctions put all five named parties inside OFAC's existing restrictions on property held by US persons or moving through US jurisdiction. Exchanges, custodians, and payment processors now have to block any property the designated parties have an interest in when it comes into their possession or control, unless an OFAC license or exemption applies.
The blocking requirement reaches beyond the five published names. Any company owned 50% or more, directly or indirectly, by one or more blocked persons is also covered. Compliance teams may need to trace ownership structures to find entities Treasury didn't name.
No conversion, but a 10-day clock
A US-regulated crypto company that identifies assets belonging to a blocked person must deny access to them and report the property to OFAC within 10 business days. The agency doesn't require firms to sell frozen crypto into dollars. Custodians can hold the assets in their existing form while preventing sanctioned parties from accessing or transferring them. Blocked assets also carry annual reporting requirements.
OFAC treats digital assets the same way it treats fiat currency and other property. That's not new policy, but it's the framework firms are working from here.
Secondary sanctions, and where they stop
Treasury warned that foreign financial institutions could face secondary sanctions for knowingly facilitating significant transactions for parties designated under the relevant authority. That provision is not a worldwide freeze on every blockchain transaction tied to the sanctioned parties. Enforcement depends on jurisdiction, ownership, whether blocked property is involved, and in some cases the significance of the transaction and what the institution knew about it.
The next test for crypto firms is whether US authorities publish or identify additional wallet addresses, intermediaries, or entities connected to the network. Until that happens, compliance teams are working from the five names and the ownership rule — and watching for more.
