In one week, the U.S. Treasury sanctioned a network that funded Hamas through sham charities and crypto assets, and hit Tren de Aragua for stealing millions from banks through ATM attacks. Illicit money hides behind a good cause or vanishes into digital wallets.
1. KYC/AML: When "charity" is the front
On October 2, the Office of Foreign Assets Control (OFAC) designated a France-based network that, according to Treasury, moved more than $2 million to Hamas between 2020 and 2026 through front charities and crypto transfers. Two fundraisers ran entities that solicited donations for supposedly humanitarian purposes, then sent crypto to an operative in Gaza who also promoted the campaigns on social media.
The lesson for compliance teams is twofold. First, non-profit organizations (NPOs) require risk-based due diligence: know who runs the entity, where donations come from and where the funds go. Second, monitoring must bridge traditional finance and crypto: donation deposits that end up at exchanges or unhosted wallets are a signal worth reviewing.
2. GAFILAT
No official updates in the last four days. As useful context, its regional forum in mid-September focused precisely on risks in the insurance and NPO sectors.
3. Dominican Republic
No new rules from the Superintendency of Banks and no statements from the UAF since the October 2 financial inclusion guide for older adults, covered in our previous edition. It is a good moment for institutions to review their watchlists: this week's OFAC designations include Mexico-based companies and affect any institution with U.S. dollar correspondent relationships.
4. Latin America: Tren de Aragua and ATM "jackpotting"
On September 30, OFAC sanctioned ten targets linked to Tren de Aragua, including the alleged leader of an ATM jackpotting scheme (malware that forces machines to dispense cash without debiting any account), a senior figure directing operations in South America and two Mexico-based businesses. According to Treasury, by August 2025 the scheme had caused $40.73 million in losses across more than 1,500 attacks in the U.S., with the proceeds laundered through crypto before being distributed to members in several countries, including Venezuela and Colombia.
On the same day, new OFAC Cuba regulations took effect, along with an alert warning of heightened sanctions risk in transactions involving the island. For banks, remittance companies and fintechs in the region, both moves mean updating lists, reviewing counterparties and better documenting the source of funds.
Practical takeaways for regulated companies
- Update your screening today: load the September 30 and October 2 OFAC designations and run retroactive matches.
- Strengthen NPO due diligence: verify directors, donation sources and fund destinations, especially where fundraising happens on social media.
- Connect fiat and crypto: set alerts for donation or cash flows that end up at exchanges or unhosted wallets.
- Look at cash differently: unusual ATM withdrawals and structured deposits can be the final stage of a tech-enabled fraud.
- Review your Cuba exposure: check whether clients or correspondents have transactions affected by the new rules.
At Global KYC & Compliance Solutions, we automate screening, monitoring and due diligence so your team can focus on the cases that require expert judgment.
Sources
- U.S. Treasury – Hamas financing network (Oct 2, 2026)
- U.S. Treasury – Sanctions on Tren de Aragua financial network (Sep 30, 2026)
- OFAC – Recent actions, Cuba regulations (Sep 29, 2026)
- OFAC – Counter terrorism designations (Oct 2, 2026)
- GAFILAT – Regional forum on insurance and NPOs
- DR Superintendency of Banks – Regulations