ASK MAT – after a large fundraising event, I’ve been asked for a corporate donation to a “humanitarian camp” in Gaza. Should I do any checks?

ASK MAT – I’m an MD at a local financial services business. After a large fundraising event, I’ve been asked for a corporate donation to a “humanitarian camp” in Gaza, named ABC Camp in Gaza (ABCG*). Should I do any checks on ABCG? Should I be paying them directly?

MAT SAYS:- Donating proceeds from an event to ABC Camp in Gaza (ABCG) carries potential SANCTION AND TERRORIST FINANCING (STF) RISKS that require careful consideration due to the complex political, legal, and financial environment surrounding humanitarian aid in the region.

Executive summary

Participation in, donation to, or engagement with activities related to ABC Camp in Gaza (ABCG) carries inherent risks due to the complex and volatile environment in which it operates.

• These risks include, but are not limited to:

1. Geopolitical and Security Risks
• The Gaza region is subject to ongoing conflict, political instability, and unpredictable security conditions. Violence, military actions, or sudden changes in local governance may disrupt operations.
• Travel warnings or restrictions issued by governments may limit access to the region, affecting program delivery or volunteer safety.
2. Financial and Donation Risks
• Contributions to ABCG are made at the donor’s own risk. While efforts are made to ensure funds are used for their intended purpose, external factors such as local regulations, economic instability, or logistical challenges may impact the allocation or effectiveness of donations.
• There is no guarantee of specific outcomes or results from funded programs due to the unpredictable nature of operating in a conflict zone.
3. Operational Risks
• Delivery of humanitarian aid, services, or programs may be delayed, disrupted, or cancelled due to factors beyond ABCG’s control, including infrastructure damage, supply chain interruptions, or restrictions imposed by local authorities.
• Volunteers or staff engaging with ABCG activities may face personal safety risks, including exposure to violence, injury, or health hazards.
4. Legal and Compliance Risks
• Activities in Gaza may be subject to local and international laws, sanctions, or regulations, which could affect ABCG’s operations or the ability to accept donations from certain jurisdictions.
• Donors and participants are responsible for ensuring their involvement complies with applicable laws in their country of residence.
5. Reputational Risks
• Association with activities in a highly publicised and sensitive region like Gaza may attract public scrutiny or criticism, potentially affecting participants’ or donors’ personal or professional reputations.

Below is a detailed analysis based on the limited information you have supplied me, along with available information

Key Considerations for STF Risk

1. U.S. and International Sanctions on Gaza-Based Entities:
   1. OFAC has targeted sham charities like Al Weam Charitable Society, which was found to be controlled by Hamas and used to raise funds under the guise of humanitarian work.
• The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has imposed sanctions on entities and individuals in Gaza accused of funnelling funds to terrorist organisations, such as Hamas and the Popular Front for the Liberation of Palestine (PFLP). For example:
• If ABCG or its associated entities are linked to sanctioned groups like Hamas or PFLP, donating to them could violate such legal instruments/orders as the U.S. sanctions under Executive Order 13224, which prohibits transactions with designated terrorist organisations or their supporters.
• Violating these sanctions can result in severe penalties, including fines, asset freezes, or criminal charges for U.S. persons or entities.
2. Lack of Information on ABCG:
• There is no specific mention of "ABCG " in widely available public sources as a recognised refugee camp or humanitarian organisation in Gaza.
• Gaza’s known refugee camps include Jabalia, Beach (Al Shati), Nuseirat, Bureij, and Deir Al Balah, among others.
• If ABCG is not a registered or recognised entity (e.g., with UNRWA or other international NGOs), there is a risk that it could be an informal or unverified operation, increasing the likelihood of sanctions exposure.
• Donors must verify the camp’s legitimacy, its leadership, and how funds are managed to ensure compliance with international laws.
3. Challenges with Aid Distribution in Gaza:
   1. Hamas has been known to exploit charitable networks, using them as fronts for fundraising.
   1. UNRWA, Oxfam, or the International Red Cross, which have established mechanisms to deliver aid in Gaza.
• Gaza is under a stringent Israeli blockade, which has restricted humanitarian aid, including food, water, and medical supplies, since at least March 2025.
• The blockade and ongoing conflict create a high-risk environment for aid delivery, as funds could inadvertently be diverted to sanctioned groups. For instance:
• Donors must ensure that funds reach intended beneficiaries (e.g., civilians in ABCG ) and are not redirected to military or terrorist activities. This requires robust due diligence, such as partnering with reputable organisations like:
4. Legal and Reputational Risks:
   1. The U.S. and UK have sanctioned entities like Gaza Now for fundraising for Hamas post-October 2023.
• Even if ABCG is a legitimate humanitarian effort, the lack of transparency in Gaza’s aid ecosystem increases the risk of inadvertently violating sanctions. For example:
• Beyond legal risks, there is a reputational risk for event organisers if donations are perceived as supporting controversial or sanctioned groups, especially given the polarised global discourse on the Israel-Palestine conflict.
5. International Humanitarian Law and Neutrality:
• Amnesty International and other organisations have criticised alternative aid distribution mechanisms, such as those controlled by Israeli authorities or private security firms, as potentially violating international humanitarian law principles of impartiality, neutrality, and independence.
• Donating to an unverified entity like ABCG could raise questions about compliance with these principles, particularly if the camp is not coordinated with established humanitarian agencies.

Recommendations to Mitigate STF Risks

To minimise sanction risks while donating proceeds to ABCG, consider the following steps:

1. Verify the Recipient:
• Confirm whether ABCG is a registered entity or part of an established refugee camp network (e.g., under UNRWA’s oversight).
• Contact UNRWA, which supports over 5 million Palestinian refugees, including those in Gaza’s camps, to verify if ABCG  is affiliated.
• Request documentation, such as registration details, financial transparency reports, or partnerships with recognised NGOs, to ensure the camp is a legitimate humanitarian operation.
2. Partner with Reputable Organisations:
   • UNRWA: Provides food, water, healthcare, and shelter to registered refugees. Donations are tax-deductible in several countries, and UNRWA’s Zakat program is Sharia-compliant.
   • Oxfam: Has reached over 1.2 million people in Gaza with food, water, and sanitation support since October 2023.
   • UNICEF: Focuses on child protection, nutrition, and water supply, reaching 1.5 million people in Gaza.
   • Islamic Relief: Active in Gaza since 1994, providing food, water, and medical aid.
• Route donations through trusted international organisations with a proven track record in Gaza, such as:
• These organisations have mechanisms to ensure compliance with sanctions and international law, reducing the risk of funds being misused.
3. Conduct Due Diligence:
• Screen ABCG and its leadership against OFAC’s Specially Designated Nationals (SDN) list and other sanctions lists (e.g., EU, UK, or UN sanctions).
• Engage a legal or compliance expert to review the donation process and ensure alignment with U.S. and international regulations.
4. Ensure Transparency in Fund Allocation:
• Request a clear breakdown of how funds will be used (e.g., food, water, medical supplies) and ensure they are directed to civilian beneficiaries.
• Use escrow accounts or third-party audited channels to track and verify the distribution of funds.
5. Monitor Political and Legal Developments:
   • Israel’s ban on UNRWA operations in 2025 has complicated aid delivery, increasing reliance on alternative channels that may carry higher risks.
• Stay informed about updates to sanctions lists and Gaza’s humanitarian situation. For example:
• Check with the U.S. Treasury or relevant authorities if you are unsure about the legal status of donating to a specific entity in Gaza.
6. Consider Alternative Donation Models:
• If direct donation to ABCG poses too high a risk, consider supporting broader appeals, such as the Disasters Emergency Committee (DEC) Middle East Humanitarian Appeal, which supports Gaza, Lebanon, and other regions.
• Monthly donations to established charities provide sustained support and reduce the risk of one-off contributions being misdirected.
7. Conclusion
• Donating proceeds to ABCG in Gaza carries potential sanction risks due to the lack of clear information about the camp’s status, the complex sanctions environment targeting Hamas and PFLP-linked entities, and the challenge of ensuring aid reaches civilians amidst Gaza’s blockade and conflict.
• To mitigate these risks, verify the camp’s legitimacy, partner with reputable organisations like UNRWA or Oxfam, and conduct thorough due diligence to ensure compliance with U.S. and international sanctions.
• If direct donation to ABCG is not feasible, redirecting funds to established humanitarian agencies active in Gaza is a safer and more effective way to support civilians in need.

INFORMATION SOURCES TO CONSIDER

• U.S. Treasury OFAC Specially Designated Nationals (SDN) List: https://sanctionssearch.ofac.treas.gov/
• UNRWA Donation Page: https://www.unrwa.org/donate-now
• Oxfam Gaza Crisis Appeal: Donate to Gaza - Gaza Crisis Appeal | Oxfam GB
• UNICEF Gaza Humanitarian Response: UNICEF in emergencies | UNICEF
• Islamic Relief Gaza Emergency Appeal: Donate to Gaza - Gaza Appeal | Islamic Relief UK
• Disasters Emergency Committee (DEC) Middle East Humanitarian Appeal: https://www.dec.org.uk/appeal/middle-east-humanitarian-appeal
• U.S. Treasury OFAC Sanctions Compliance Guidance: https://home.treasury.gov/policy-issues/financial-sanctions/sanctions-compliance-and-evaluation

*ABC Camp in Gaza (ABCG*).  –   Risk Warning: ABC Camp in Gaza (ABCG) - Disclaimer:

• ABC Camp in Gaza (ABCG) is a fictional entity created solely for this case study. Any resemblance to real charities, organisations, or entities with similar names is purely coincidental and unintentional.
• Fictional Context
  As a fictional entity created for this case study, ABCG does not exist and does not conduct real-world operations. This risk warning is designed to simulate considerations for organisations operating in similar contexts. No actual donations, participation, or activities should be undertaken based on this case study.
• Recommendation
  Before engaging with any real-world organisation operating in high-risk areas, individuals should conduct thorough due diligence, consult with legal and financial advisors, and assess their personal risk tolerance.