On October 2, 2026, the U.S. Office of Foreign Assets Control (OFAC) added five individuals and charities tied to a Hamas financing network to the Specially Designated Nationals (SDN) List under Executive Order 13224, as amended by E.O. 13886. The designations, published on OFAC's recent actions page, name Saleem Abdallah Saleem al-Zaq, Faouzi Barika, Amel Oualid, Association Baraka, and Ensemble C Mieux, and expose every dollar-clearing or donation-routing counterparty to blocking sanctions.
US banks and money services businesses that screen the SDN List, US and EU cryptocurrency exchanges and virtual-asset service providers, US payment processors and correspondent banks, French banks and payment firms that hold accounts for Association Baraka or Ensemble C Mieux, and US and French donation platforms and NGOs that route Gaza-related fundraising must immediately screen customers, counterparties, wallets, and charity names against the five new entries and block any property or interest in property of those persons and entities, or face IEEPA civil penalties on a strict-liability basis and, for non-US persons, secondary sanctions risk under section 1(b) of E.O. 13224 as amended by E.O. 13886.
Who must screen the new SDN entries?
The designations sit at the intersection of two channels Treasury says financed Hamas: a cryptocurrency and charity fundraising network that raised more than $2 million, including hundreds of thousands of dollars in virtual assets, and a French nonprofit layer that routed donations through Association Baraka and Ensemble C Mieux. Exposure turns on market activity, not domicile: any transaction touching the US financial system or a US person pulls a counterparty inside OFAC jurisdiction, and section 1(b) of E.O. 13224 extends the risk to non-US firms that conduct significant transactions with the designated parties.
French banks and payment firms face the most direct national exposure, because both designated charities are French-registered: Association Baraka (charity number W331005557, in Saint-André-de-Cubzac) and Ensemble C Mieux (charity number W423015492, in Saint-Étienne), operated by the designated French and Algerian nationals Faouzi Barika and Amel Oualid. US and French donation platforms and NGOs that routed Gaza-related fundraising to either charity must review their donor and beneficiary records against the five names.
What was added to the SDN List on October 2, 2026?
| Name | Type | Location | Linked to |
|---|---|---|---|
| Saleem Abdallah Saleem al-Zaq | Individual (SDGT) | Gaza | HAMAS |
| Faouzi Barika | Individual (SDGT) | Saint-André-de-Cubzac, France | HAMAS |
| Amel Oualid (a.k.a. Amel Bouchekif) | Individual (SDGT) | Saint-Étienne, France | al-Zaq |
| Association Baraka | Charity (SDGT) | Saint-André-de-Cubzac, France | Barika |
| Ensemble C Mieux ("Together It's Better") | Charity (SDGT) | Saint-Étienne, France | Oualid |
All five entries carry the SDGT tag (Specially Designated Global Terrorist) and the same secondary sanctions risk clause. Treasury's same-day press release sb0647 states the network raised more than $2 million for Hamas, including hundreds of thousands of dollars in cryptocurrency, and the Department of Justice announced a parallel indictment of Saleem Alzaq with arrests in the United States and France on October 2, 2026. The OFAC 50 Percent Rule also applies: any entity 50 percent or more owned in the aggregate by a blocked person is itself blocked, even if not separately listed.
What must compliance teams do immediately?
- Screen customer bases, counterparty lists, wallet addresses, and charity names against the five new SDN entries, including the aliases Saleem A.S. Alzaq, Salim Zak, and Amel Bouchekif.
- Block any property or interest in property of the designated persons and entities, and reject or report matches under your OFAC reporting procedures.
- Apply the 50 Percent Rule to any entity 50 percent or more owned by Association Baraka, Ensemble C Mieux, or the three individuals, even if that entity is not separately listed.
- Review donation, payment, and crypto transaction records back to the charities' establishment dates (Association Baraka October 13, 2023; Ensemble C Mieux July 1, 2024) for prior exposure.
- Confirm that US-person prohibitions are enforced: US persons are prohibited from dealing with the designated parties, and correspondent banks must reject dollar-clearing touches.
What happens if a US person or non-US firm fails to block?
IEEPA civil penalties attach on a strict-liability basis, meaning intent is not required for a violation to attach, and voluntary self-disclosure materially reduces the penalty under 31 CFR Part 501, Appendix A. US persons are prohibited from dealing in any property or interests of the designated parties and must block them. Non-US persons that engage in significant transactions with the five designated parties face secondary sanctions risk under section 1(b) of E.O. 13224, as amended by E.O. 13886, which can cut them off from the US financial system and USD clearing. Continuous, per-jurisdiction monitoring of the SDN List surfaces a designation the moment OFAC publishes it, before a blocked payment clears.
Verify whether your customer, counterparty, wallet, or charity name matches the October 2, 2026 SDN additions, confirm your blocking and reporting procedures are wired to the SDN feed, brief sanctions screening and donation-platform teams on the French charity layer, and re-run transaction history for prior exposure to Association Baraka or Ensemble C Mieux.
