Designation under E.O. 13224 means OFAC has determined the person/entity is linked to terrorism; U.S. property and interests in property of the designated party are blocked, U.S. persons are generally prohibited from dealing with them, and the designee is added to OFAC’s SDN/blocked list—exposure to civil/criminal penalties and possible secondary sanctions follows.
Practically, donations to the designated groups are prohibited for U.S. persons and can be blocked; any U.S.-held bank accounts or assets of the groups are frozen; banks and intermediaries may refuse transactions involving them; people in Gaza receiving services from these organizations risk those groups’ funds being blocked and aid partners/donors face legal and reputational risk.
OFAC’s humanitarian general licenses (published in Dec. 2022 and reiterated in Nov. 2023 guidance) authorize certain categories of humanitarian transactions—e.g., approved activities by U.S. government, certain international organizations, NGOs, and deliveries of medicine/medical devices—so legitimate humanitarian aid to Palestinians/Gaza can proceed if it fits authorized categories or is licensed by OFAC; donors must still do due diligence to avoid prohibited dealings with designated actors.
Donors/charities should (1) screen recipients and intermediaries against OFAC’s SDN and consolidated lists; (2) follow OFAC’s humanitarian guidance and applicable general licenses; (3) perform enhanced due diligence (beneficiary identification, recordkeeping, monitoring); and (4) consult OFAC or seek a specific license when there is risk of links to designated groups.
The Popular Conference for Palestinians Abroad (PCPA) is an organization that purports to represent the Palestinian diaspora but, according to Treasury, was clandestinely controlled and directed by Hamas, involved in organizing flotillas to access Gaza, and used by Hamas to expand political influence abroad.
Zaher Khaled Hassan Birawi is a United Kingdom–based senior official and founding member of the PCPA’s General Secretariat; OFAC designated him for materially assisting or providing support to the PCPA (a Hamas front), per the Treasury press release.
Treasury said it used documentary evidence seized from Hamas offices after October 7, 2023 (financial records and internal documents) showing transfers and operational instructions (e.g., records showing Al‑Falah sent over $2.5 million to Hamas). Treasury’s statement does not publish that documentary evidence for public review; OFAC provided a summary in its press release.
Secondary sanctions are penalties the U.S. can impose on foreign persons/institutions that knowingly engage in significant transactions with designated parties (e.g., blocking access to U.S. correspondent accounts, restricting U.S. market access); foreign banks or organizations dealing with designated entities risk losing U.S. dollar services, correspondent banking access, or facing other U.S. sanctions.