The US Treasury Department announced today (Monday) that it was imposing a fifth round of sanctions against Hamas funding networks, especially those based in Gaza, in cooperation with the UK and Australia.
According to the release, the sanctions will target the Gaza based Shamalkh network and the Herzallah network, both of whom facilitate the transfer of large amounts of money from sources such as Iran to Hamas, including through cryptocurrency accounts.
The release did note that "OFAC sanctions programs contain provisions for legitimate humanitarian support to vulnerable populations, including authorizations for certain humanitarian transactions in support of nongovernmental organizations’ activities."
According to the official Supplemental Guidance on this subject, UN and other authorized humanitarian NGOs may operate in sanctioned areas so long as they do not knowingly provide assistance to sanctioned individuals or groups.
Whether this is sufficient given the increasing Israeli exposure of groups like UNRWA as being thoroughly infiltrated by Hamas operatives remains an open question.