As more Hamas leaders come under international sanction, their relationship with international aid agencies and charities has come under scrutiny. The United Nations Relief and Works Agency for Palestine Refugees in the Near East (UNRWA) is a UN agency that is meant to provide essential services to Palestinians who fled or were displaced during the 1948 War of Independence. With a staff of over 30,000, primarily Palestinians, UNRWA operates in Gaza as well as Jordan, Lebanon, Syria and the West Bank, with a mandate to provide medical care, education, and other social services to vulnerable families and individuals.

While there has long been tension over UNRWA’s controversial relationship with Hamas, recent events have cast a darker shadow over UNRWA’s operations and several donor states, including Germany, Britain, Italy, Australia, and Finland, announced on 27 January that they were halting funding to UNWRA following allegations of staff involvement in and support for the October 7 massacre in Israel orchestrated by Hamas terrorists. The defunding and firing of several accused members comes on the heels of the recent decisive action taken by the European Union’s Council to add Yahya Sinwar, Hamas’ leader in the Gaza Strip who has been under US sanctions since 2015, to its terrorist list for his involvement in the October 7 attacks, as well as dozens of other new sanctions on Hamas members by several countries in the past three months. Those on the terror lists are subject to asset freezes and citizens of and organisations in countries in which the sanctions have been imposed are barred from conducting financial transactions with them.

As the international community grapples with the complexities of funding humanitarian aid in conflict zones, adherence to sanctions and AML regulations emerge as a cornerstone of ethical conduct and legal compliance. Prioritising compliance in these areas can help businesses uphold the principles of transparency, accountability, and respect for international law, ensuring that their efforts contribute positively to the well-being of affected populations while mitigating the risk of inadvertent support for sanctioned entities or activities.

In this context, robust compliance mechanisms are indispensable safeguards to ensure that funds intended for humanitarian aid do not inadvertently support sanctioned individuals or entities. Organisations must prioritise the implementation of rigorous screening processes and compliance training programs to mitigate the risk of association with sanctioned individuals or entities, thereby upholding the integrity of their humanitarian missions.

Sanctions compliance software and training solutions empower organisations to proactively identify and address compliance risks while maintaining transparency and accountability. As donor states reassess their contributions to UNRWA in light of allegations implicating some of its staff in Hamas’ activities, the need for comprehensive due diligence and ongoing monitoring becomes paramount. By prioritising sanctions compliance, organisations can ensure that their funds are used for their intended purpose, ensuring that their efforts contribute positively to the well-being of affected populations while mitigating the risk of inadvertent support for sanctioned entities or activities.