Agendas · MEF Policy Notes
Terrorist Finance: Hamas and Hezbollah Money Trails
Money reaching Hamas and Hezbollah through Turkish markets, crypto accounts, gold, and Latin American networks.
What the Notes Find
Trend GYO, designated by Treasury as 75 percent owned by Hamas, trades on the Borsa Istanbul. (MEF-PN-2026-06) An FBI affidavit filed in March 2025 traced Qassam Brigades crypto donations to accounts held by Palestinians with Turkish identity documents. (MEF-PN-2026-06) Hezbollah’s revenue lines run through a gold and shadow-bank channel in Lebanon, a Turkish corridor and Latin America, where MEF’s Jose Lev Alvarez counts Treasury designations of more than 100 Hezbollah-linked individuals and entities in at least ten countries over two decades. (MEF-PN-2026-05) State and Treasury listed the Lebanese, Jordanian and Egyptian Muslim Brotherhood chapters as Specially Designated Global Terrorists for support to Hamas. (MEF-PN-2026-03)
Reading Order
1 of 3 · MEF-PN-2026-06
Turkey and Hamas: Sanctuary, Money and U.S. Exposure
Turkey hosts Hamas officials and a listed company that Treasury designated as 75 percent Hamas-owned, while remaining a NATO ally and U.S. arms customer.
Findings
- Core point: Turkey hosts Hamas leaders and allows rallies praising Hamas while seeking a role in Gaza and new U.S. aircraft.
- On the record: Treasury designated Musa Daud Muhammad Akari, a senior Hamas official based in Turkey, a Specially Designated Global Terrorist on November 19, 2024.
- Follow the money: An FBI affidavit filed in March 2025 traced Qassam Brigades crypto donations to accounts held by Palestinians with Turkish identity documents.
- Corporate footprint: Trend GYO, designated by Treasury as 75 percent owned by Hamas, trades on the Borsa Istanbul.
- Contested: Some Washington analysts see Turkey as a stabilizing partner; MEF’s Michael Rubin argues that “it is not possible to be both pro-Turkey and anti-Hamas.”
Questions for Oversight
- What has Treasury asked of Turkey regarding designated Hamas officials resident there, including Musa Akari?
- How do Turkish exchanges and banks respond to U.S. requests on accounts that received Qassam Brigades donations, given the FBI’s stated concern about BTCTurk?
- How are listed companies designated for Hamas ownership, such as Trend GYO, treated under U.S. secondary sanctions?
- What technology-security reviews apply to pending arms transfers to Turkey while it operates the S-400?
- What is the State Department’s assessment of Hamas fundraising and recruitment at public events in Turkey?
- How does Turkey’s relationship with Hamas factor into U.S. planning for postwar Gaza?
2 of 3 · MEF-PN-2026-05
Hezbollah’s Finance Networks After the War
Battlefield losses have not closed Hezbollah’s revenue lines.
Findings
- Core point: Hezbollah’s financial network remains largely intact even after Israel killed its top field commanders.
- On the record: Treasury’s February 10, 2026 action targeted a gold-for-cash front run under al-Qard al-Hassan and a shipping network routed through Turkey.
- Hemisphere reach: MEF’s Jose Lev Alvarez counts Treasury designations of “more than 100 Hezbollah-linked individuals and entities across at least ten Latin American countries over the past two decades.”
- Transit route: Mahan Air flew 11 Tehran to Beirut flights over Turkish airspace in the last weeks of 2024 after Syrian airspace closed.
- Handle with care: The often-cited figure of at least $200 million a year from the Tri-Border Area is an analysts’ estimate, not an audited total.
Questions for Oversight
- How has Treasury measured the effect of the February 2026 designations on al-Qard al-Hassan’s conversion of gold into cash?
- What action has Turkey taken on the Turkish-registered companies named in February 2026, and what has the United States requested?
- How are cash shipments on commercial flights into Beirut monitored with Lebanese authorities?
- Which Latin American governments share designation and financial-intelligence data with Treasury, and how is Brazil engaged?
- How does U.S. assistance to the Lebanese Armed Forces take account of Hezbollah’s remaining financial capacity?
- How do counternarcotics and terrorist-finance units coordinate on trade-based money laundering that benefits Hezbollah?
3 of 3 · MEF-PN-2026-03
Designating the Muslim Brotherhood: The Record So Far
The United States now lists Muslim Brotherhood chapters one at a time.
Findings
- Core point: U.S. policy now designates named Muslim Brotherhood chapters rather than the movement as a whole.
- On the record: Executive Order 14362 was signed on November 24, 2025; Federal Register notices listing Lebanon’s chapter as a Foreign Terrorist Organization appeared on January 14, 2026, and Sudan’s on March 16, 2026.
- Also listed: State and Treasury listed the Lebanese, Jordanian and Egyptian chapters as Specially Designated Global Terrorists for support to Hamas.
- Allied practice: Egypt, Saudi Arabia, the UAE and Bahrain have long banned the Brotherhood as a terrorist organization; Jordan banned it in mid-2025.
- Open file: Yemen’s Islah party, co-founded by a cleric Treasury designated in 2004, has denied Brotherhood ties four times since 2013.
Questions for Oversight
- What criteria does the State Department apply in deciding which national chapters meet the statutory standard, and which chapters remain under review?
- How does Treasury distinguish the designated chapters from charities and companies that share their leaders or funding?
- What is the current assessment of Islah, given the 2004 designation of its co-founder and the 2016 designation of a branch head?
- How are publicly traded companies designated for Hamas ownership, such as Trend GYO, handled with allied market regulators?
- How are evidence and listing criteria coordinated with Egypt, Saudi Arabia, the UAE, Bahrain and Jordan?
- What reporting to Congress accompanies listings under Executive Order 14362, and on what schedule?
Bills Cited in These Notes
| Bill | Title | Cited In | Text and Status |
|---|---|---|---|
| H.J.Res. 200 | Providing for congressional disapproval of the proposed foreign military sale to Turkey of certain defense articles and services. | MEF-PN-2026-06 | Congress.gov · Middle East Legislation in Congress |
| H.Res. 1379 | Condemning Lebanese Hezbollah's repeated violations of ceasefire agreements and calling for the Lebanese Government to ensure Lebanese Hezbollah immediately ceases all attacks and disarms, in accordance with the ceasefire. | MEF-PN-2026-05 | Congress.gov · Middle East Legislation in Congress |
| S. 2293 | Muslim Brotherhood Terrorist Designation Act of 2025 | MEF-PN-2026-03 | Congress.gov · Middle East Legislation in Congress |