United States and Canada designate “Samidoun,” a sham charity that serves as an international fundraiser for the PFLP terrorist organization

United States and Canada designate “Samidoun,” a sham charity that serves as an international fundraiser for the PFLP terrorist organization

Today, in a joint action with Canada, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated the Samidoun Palestinian Prisoner Solidarity Network, or “Samidoun,” a sham charity that serves as an international fundraiser for the Popular Front for the Liberation of Palestine (PFLP) terrorist organization. The PFLP, which was designated as a Foreign Terrorist Organization and a Specially Designated Global Terrorist by the U.S. Department of State in October 1997 and October 2001, respectively, uses Samidoun to maintain fundraising operations in both Europe and North America. Also designated today is Khaled Barakat, a member of the PFLP’s leadership. Together, Samidoun and Barakat play critical roles in external fundraising for the PFLP. Today’s action is being taken pursuant to the counterterrorism authority Executive Order (E.O.) 13224, as amended.

In a coordinated effort, the Government of Canada has listed Samidoun as a terrorist entity under its Criminal Code, effective Friday, Oct. 11. The listing of an entity is a public means of identifying a group or individual as being associated with terrorism. The Criminal Code prohibits certain actions in relation to terrorist groups, including those related to terrorist financing, such as knowingly dealing with any property that belongs to a terrorist.

“Organizations like Samidoun masquerade as charitable actors that claim to provide humanitarian support to those in need, yet in reality divert funds for much-needed assistance to support terrorist groups,” said Acting Under Secretary of the Treasury for Terrorism and Financial Intelligence Bradley T. Smith. “The United States, together with Canada and our like-minded partners, will continue to disrupt those who seek to finance the PFLP, Hamas, and other terrorist organizations.”

“Canada remains committed to working with our key partners and allies, like the United States, to counter terrorist organizations and their fundraisers,” remarked the Honourable Dominic LeBlanc, Canadian Minister of Public Safety, Democratic Institutions and Intergovernmental Affairs. “Today’s joint action with the U.S. sends a strong message that our two nations will not tolerate this type of activity and will do everything in our power to ensure robust measures are in place to address terrorist financing.”

In coordination with Canada, OFAC is targeting a sham fundraiser whose efforts have supported terrorism. When terrorists and terrorist organization abuse the non-profit sector, legitimate organizations have more difficulty securing financial services. This impacts their ability to provide support for basic human needs like food, medicine, and shelter in Gaza and the West Bank. By publicly identifying sham charities, this action reduces the overall risk of the NPO sector and preserves access by legitimate humanitarian organizations to financial services. This action builds on OFAC’s recent action on October 7, 2024, which sought to expose terrorists and terrorist organizations that abuse the non-profit organization sector by raising funds under the guise of charitable work, and was also enabled by key data from Treasury’s Financial Crimes Enforcement Network (FinCEN).

THE POPULAR FRONT FOR THE LIBERATION OF PALESTINE (PFLP)

The PFLP is a terrorist group operating in Gaza and the West Bank. It has been a designated FTO since 1997 and is the second largest Palestine Liberation Organization (PLO) faction despite boycotting PLO meetings since 2018. PFLP remained committed to terrorist activity through its armed apparatus, the Martyr Abu Ali Mustafa Brigades, and the group has been active in the Israel-Hamas conflict, to include participating in the horrific attacks against Israeli civilians on October 7, 2023. PFLP has not held any leadership positions in the PLO since 2016.

PFLP FUNDRAISERS: SAMIDOUN AND BARAKAT

The Samidoun Palestinian Prisoner Solidarity Network (Samidoun), a front organization based in Vancouver, Canada and established by the PFLP, is involved in fundraising for the PFLP. Samidoun serves as a front for the group in countries where the PFLP is declared a terrorist organization. While the organization ostensibly supports Palestinian prisoners and their family members, in practice Samidoun provides financial support to the sanctioned PFLP. In addition to today’s joint action with Canada, Samidoun was also banned by Germany in a separate November 2023 action.

Khaled Barakat (Barakat) is a Canadian citizen and a member of the PFLP and serves as part of the group’s leadership abroad. His fundraising and recruitment efforts support the PFLP’s terrorist activity against Israel. Barakat has previously publicly acknowledged Samidoun’s affiliation with the PFLP, despite direction from PFLP leadership to maintain the confidential nature of the relationship.

Samidoun is being designated pursuant to E.O. 13224, as amended, for being owned, controlled, or directed by, or having acted for or on behalf of, directly or indirectly, the PFLP. Barakat is being designated pursuant to E.O. 13224, as amended, for having acted or purported to act for or on behalf of, directly or indirectly, the PFLP.

SANCTIONS IMPLICATIONS

As a result of today’s action, all property and interests in property of the designated persons described above, and of any entities that are owned directly or indirectly, 50 percent or more by them, individually, or with other blocked persons, that are in the United States or in the possession or control of U.S. persons are blocked and must be reported to OFAC. Unless authorized by a general or specific license issued by OFAC, or exempt, OFAC’s regulations generally prohibit all transactions by U.S. persons or within (or transiting) the United States that involve any property or interests in property of designated or otherwise blocked persons.

U.S. persons must comply with OFAC regulations, including all U.S. citizens and permanent resident aliens regardless of where they are located, all persons within the United States, and all U.S.-incorporated entities and their foreign branches. Non-U.S. persons are also subject to certain OFAC prohibitions. For example, non-U.S. persons are prohibited from causing or conspiring to cause U.S. persons to wittingly or unwittingly violate U.S. sanctions, as well as engaging in conduct that evades U.S. sanctions. Violations of OFAC regulations may result in civil or criminal penalties.

In addition, non-U.S. financial institutions and other persons that engage in certain transactions or activities with sanctioned entities and individuals may expose themselves to sanctions risk or be subject to an enforcement action. The prohibitions include the making of any contribution or provision of funds, goods, or services by, to, or for the benefit of any designated person, or the receipt of any contribution or provision of funds, goods, or services from any such person.

OFAC may impose civil penalties for sanctions violations based on strict liability, meaning that a person subject to U.S. jurisdiction may be held civilly liable even if such person did not know or have reason to know that it was engaging in a transaction that was prohibited under sanctions laws and regulations administered by OFAC. OFAC’s Economic Sanctions Enforcement Guidelines provide more information regarding OFAC’s enforcement of U.S. economic sanctions, including the factors that OFAC generally considers when determining an appropriate response to an apparent violation. For additional information on complying with U.S. sanctions and export control laws, please see Department of Commerce, Department of the Treasury, and Department of Justice Tri-Seal Compliance Note.

Furthermore, engaging in certain transactions with the individuals designated today entails risk of secondary sanctions pursuant to E.O. 13224, as amended. Pursuant to this authority, OFAC can prohibit or impose strict conditions on the opening or maintaining in the United States of a correspondent account or a payable-through account of a foreign financial institution that knowingly conducted or facilitated any significant transaction on behalf of a Specially Designated Global Terrorist.

The power and integrity of OFAC sanctions derive not only from OFAC’s ability to designate and add persons to the Specially Designated Nationals and Blocked Persons (SDN) List, but also from its willingness to remove persons from the SDN List consistent with the law. The ultimate goal of sanctions is not to punish, but to bring about a positive change in behavior. For information concerning the process for seeking removal from an OFAC list, including the SDN List, please refer to OFAC’s Frequently Asked Question 897 here. For detailed information on the process to submit a request for removal from an OFAC sanctions list, please click here.

Treasury remains committed to enabling the flow of legitimate humanitarian assistance supporting the basic human needs of vulnerable populations, while continuing to deny resources to malicious actors. Accordingly, OFAC sanctions programs contain provisions for legitimate humanitarian support to vulnerable populations, including authorizations for certain humanitarian transactions in support of nongovernmental organizations’ activities. For more information, please review relevant authorizations and guidance on OFAC’s website.