OFAC Sanctioned Gaza Crypto Exchange in Hamas Financing Action

The U.S. Treasury Department’s Office of Foreign Assets Control imposed sanctions on nine people and one entity on October 18, 2023, including Gaza-based Buy Cash Money and Money Transfer Company, its operator Ahmed M. M. Alaqad and a Bitcoin address attributed to the business.

The designations formed part of a wider action against people and financial networks that Treasury said supported Hamas. For the cryptocurrency industry, the consequential detail was OFAC’s decision to place a virtual-currency exchange—and a specific blockchain identifier—inside an immediately enforceable counterterrorism sanctions action.

The action did not prohibit Bitcoin, designate every customer of Buy Cash or establish that every transaction involving the listed address financed terrorism. It did give U.S. persons and regulated businesses a concrete address and entity against which to apply sanctions controls.

What OFAC added to its list

OFAC’s October 18 update added eight people linked directly to Hamas, Alaqad as the person linked to Buy Cash, and Buy Cash itself. The entity entry identified the company as operating from Khan Yunis in Gaza and categorized it as monetary intermediation. It also published one XBT address: 19D1iGzDr7FyAdiy3ZZdxMd6ttHj1kj6WW.

Treasury said Buy Cash provided money-transfer and virtual-currency exchange services, including Bitcoin. The department designated the company under Executive Order 13224, as amended, for allegedly providing material support, goods or services to Hamas. Alaqad was designated under the same authority for allegedly supporting Buy Cash.

As a legal consequence, property and interests in property belonging to the designated parties that were in the United States or controlled by U.S. persons were blocked and had to be reported to OFAC. Entities owned 50% or more, directly or indirectly and in aggregate, by blocked people were also blocked. Unless licensed or exempt, U.S. persons were generally prohibited from transactions involving the designated parties’ property.

The cryptocurrency evidence Treasury cited

Treasury connected the October 18 action to an earlier Israeli investigation. It said Israel’s National Bureau for Counter Terrorist Financing seized virtual-currency wallets in June 2021 during an investigation of a Hamas fundraising campaign, and that one seized address belonged to Buy Cash.

The department also alleged that the Bitcoin address published with the designation received a transfer worth more than $2,000 in September 2019 through a Türkiye-based money-services operator associated with al-Qaida. That amount was Treasury’s historical attribution for one transfer, not the address’s balance on October 18, 2023, its lifetime transaction volume or a measure of cryptocurrency funding received by Hamas.

Treasury further alleged that people involved in acquiring online infrastructure for ISIS had registered a Buy Cash account in 2017. These statements were the government’s factual basis for an administrative sanctions decision; the October 18 records were not a criminal judgment against Buy Cash or Alaqad.

Why the address-level action mattered

Publishing a blockchain address made the designation operational for exchanges, custodians, wallet-screening services and other businesses applying U.S. sanctions controls. Unlike a name alone, an address could be incorporated into automated transaction monitoring. Public-ledger visibility could also help investigators identify transactions connected to the listed endpoint.

That transparency had limits. A Bitcoin address does not, by itself, prove the identity or purpose of every sender and recipient that interacted with it. OFAC listed one address, while contemporaneous industry reporting indicated that analytics companies associated additional addresses with the business. Coinburn does not treat those broader private attributions as part of the official designation.

Associated Press reporting on October 18 also relayed Elliptic’s assessment that cryptocurrency had been a relatively small alternative funding channel for Hamas and was susceptible to tracing and disruption. That contemporaneous qualification mattered amid rapidly circulating claims about terrorist financing: the sanctions record established a targeted exchange, operator and address, but did not establish a comprehensive total for Hamas-related cryptocurrency activity.

The verified development on October 18 was therefore precise rather than sector-wide. OFAC used established counterterrorism authority against an alleged financial facilitator that handled both conventional transfers and virtual currency, converting blockchain attribution into a formal compliance obligation without making a broader finding about Bitcoin itself.