On January 22, 2024, the United States, United Kingdom, and Australia announced an additional round of coordinated sanctions designations of individuals, entities, and aircraft linked to Hamas and the Palestinian Islamic Jihad (“PIJ”). This coordinated action builds on recent joint US-UK and unilateral US designations. Our prior blog post on the October 18, 2023 US designations is available here.

US Sanctions

On January 22, 2024, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) announced a fifth round of designations targeting Hamas since October 7, 2023. The new designations of 13 individuals, six entities, and two aircraft target networks of Hamas-affiliated financial exchanges in Gaza, their owners, and associates, particularly financial facilitators in funds transfers—including cryptocurrency transfers—from the Islamic Revolutionary Guard Corps-Qods Force to Hamas and the PIJ in Gaza.

OFAC designated these sanctions targets as Specially Designated Global Terrorists (“SDGTs”) and added them to the Specially Designated Nationals and Blocked Persons List (“SDN List”). Transactions by US Persons or within the United States that involve SDGTs are generally prohibited, unless authorized by an OFAC general or specific license. Entities 50% or more owned by an SDGT or other SDNs are subject to the same prohibitions. Non-US persons engaging in activities involving an SDGT (even if there is no US nexus) could also potentially face the risk of themselves being designated under “secondary” sanctions, among other risks.

In addition to the existing humanitarian general licenses applicable to SDGTs, OFAC issued General License No. 27 (“GL 27”) and an accompanying FAQ 1159 relating to the wind-down and civil aviation transactions with newly-designated SDGT Fly Baghdad, which are authorized until GL 27’s expiration on March 22, 2024.

UK Sanctions

On January 22, 2024, the UK Government announced its third round of designations targeting Hamas since October 7, 2023. The latest designations target five individuals and one entity connected to Hamas and the PIJ networks, including Hamas and PIJ financiers who have been involved in Hamas’s increased use of crypto-currencies as a funds transfer mechanism. Each successive round of UK designations has increasingly focused on targeting group Hamas and financiers.

These UK sanctions are imposed pursuant to the UK’s Counter-Terrorism (International Sanctions) (EU Exit) Regulations 2019 (the “CTI Regulations”). Parties designated under the CTI Regulations are subject to an arms embargo, asset freeze, and travel ban, and therefore unable to enter the UK or purchase weapons and military equipment from a UK person. In addition to the designations above, Hamas and the PIJ are already both fully designated under the CTI Regulations, and are also both proscribed organisations under the UK Terrorism Act 2000.

The UK Office of Financial Sanctions Implementation (“OFSI”)’s General Licence INT 2023/3749168 authorizes certain humanitarian activity in Israel and the Occupied Palestinian Territories and will expire on May 15, 2024.

Australia Sanctions

On January 22, 2024, Australia announced that it imposed further counter-terrorism financing sanctions on Hamas-linked targets. The new sanctions target 12 persons and three entities linked to Hamas, Hizballah, and the PIJ. The individuals sanctioned include Hamas leaders, financial facilitators, and persons who have provided training to terrorist operatives, while the sanctioned entities have been targeted for facilitating the transfer of funds to Hamas. The new sanctions follow sanctions imposed by Australia in 2023 on Hamas, Hizballah, and the PIJ in their entirety, alongside 17 individuals and seven entities with links to these groups.


Ms. Lis has extensive experience advising companies on US laws relating to exports and reexports of commercial goods and technology, defense trade controls and trade sanctions — including licensing, regulatory interpretations, compliance programs and enforcement matters. She also has advised clients on national security reviews of foreign investment administered by the Committee on Foreign Investment in the United States (CFIUS), including CFIUS-related due diligence, risk assessment, and representation before the CFIUS agencies.


Julian Godfray is a senior associate in Baker McKenzie's Competition, Trade and Foreign Investment Department in London. Julian works in particular in the Firm's market-leading International Trade and Compliance & Investigations practices. Julian joined the Firm as a trainee in September 2014, and qualified in September 2016. Julian has been seconded to two FTSE 100 clients during his time at the Firm, including in the ethics and compliance team of one client. Julian has also completed secondments to the Firm's European and Competition Law Practice in Brussels in 2016, and more recently to the Firm's Madrid office in 2020, working as part of the Firm's trade compliance practice in Spain.


Daniel Andreeff’s practice focuses on US economic and trade sanctions, including those targeting Iran, Russia, Cuba, Syria, and North Korea, export controls, and anti-boycott laws. He represents clients in national security reviews before the Committee on Foreign Investment in the United States (CFIUS), and has experience in federal court litigation and congressional investigations. His pro bono practice includes providing sanctions and export control advice to a global humanitarian NGO. * Admitted in New York only. Practice in the District of Columbia is under the supervision of a member of the District of Columbia Bar.



Rob assists multinational companies on OFAC sanctions, export controls, and other trade laws in the context of compliance, licensing, internal investigations, mergers and acquisitions, government disclosures, and enforcement actions. He has experience assisting clients navigate sanctions and export control in the following sectors: semiconductor design and manufacturing, telecommunications, pharmaceuticals, consumer goods, and financial services. Rob has also assisted start-ups and medium-sized businesses encountering OFAC sanctions and export controls for the first time. Rob's pro bono practice includes providing sanctions and export control advice to a global NGO providing humanitarian relief in conflict zones. He also advises a global pro-bono law firm in advocacy matters relevant to sanctions and export controls. He has also served on the board of directors of a nonprofit working to improve the mental health environment for university students.