Terror Finance Weekly

“Sunlight is the best disinfectant.”

Welcome back,

This week, we’re coming to you live from the 2026 International Institute for Counter-Terrorism (ICT) World Summit in Herzliya, where we just wrapped up two sessions on terror financing. The first was our workshop, “Terror Financing: An Ancient Craft in the Age of AI.” The second was a round-table discussion dealing with Correspondent Banking and Financial Integrity Risks.

A recording of the workshop will soon be available on our website.

Our thanks to the ICT for hosting, and to 240 Analytics for sponsoring the workshop.

Meanwhile, away from Herzliya, economic enforcement in our region did not slow down. OFAC opened four fronts against Iran’s sanctions evasion architecture inside a single week. Appropriately, our workshop opened with a discussion about the new global strategy of economic warfare.

As always, we would love to hear what you think. Reply to this email and it will reach us.

Sharon Gal

Chief Executive Officer, CENTEF

 

Four Fronts in One Week

CENTEF ANALYSIS  ·  28 September to 4 October 2026

OFAC opened four fronts against Iran’s sanctions evasion architecture this week, but Treasury’s most significant move is not any one of them. What matters most is that Treasury filed them under a single operation name.

The first front was the designation. OFAC named Russia’s A7 Network, led by Ilan Mironovich Shor, as a significant transnational criminal organization for helping Iran evade sanctions through falsified trade documents. The action also blocked the A7A5 token, a ruble-backed token issued by Old Vector LLC.

The second was the rule. FinCEN proposed prohibiting fund transmittals involving A7 sub-agents, the entities used to disguise the network’s transactions, and issued an alert to help banks spot that activity themselves. The two instruments do different work. A designation blocks property within reach; a FinCEN rule removes access to the U.S. financial system, which is what decides whether a counterparty can clear dollars at all.

The third was industrial. Using Executive Order 13902 determinations, OFAC reached Iran’s automotive, rail and metals sectors, naming Iran Khodro, SAIPA, the Islamic Republic of Iran Railway Company, a Chinese HEPCO metals-trading unit, and parts suppliers in the UAE, Hong Kong, Indonesia and Turkey.

The fourth was procurement. A ten-entity action reached into China, Pakistan, Saudi Arabia and Turkey, targeting suppliers who sent weapons and components to Iran’s Ministry of Defense and Armed Forces Logistics, including a Beijing-based MODAFL representative.

Taken individually, each reads as a narrow, sector-specific strike. Taken together, they close parallel channels, banking and manufacturing and military procurement, that the network depends on. Grouping them under one operation name is what is notable, because it links the revenue and evasion channels directly to the acquisition pipeline they exist to fund, and folds Russia-linked evasion into the same frame rather than treating it as a separate file.

The blocked token deserves a moment on its own. We argued last month that the perimeter has to be drawn around asset properties rather than only around names, and that the operative question is which instruments have an issuer who can be served with process. A designated ruble-backed token is that argument in practice.

But it is also worth recognizing what a name does not do. A sectoral determination is broad authority rather than a result, and its effect depends on whether parts suppliers in Hong Kong, Indonesia and the UAE actually withdraw, which is a commercial calculation about dollar access rather than a legal one. Designating a car manufacturer does not stop cars being built. It raises the cost of every component that has to cross a border.

What to watch is whether the operation name starts doing work beyond branding. If subsequent tranches keep pairing a revenue channel with the procurement it funds, Treasury is building a map rather than a list, and a map is considerably harder to route around.

ALSO THIS WEEK

Our Weapons Estimate Puts Hezbollah’s 2024 Intake at $157 Million

CENTEF RESEARCH  ·  Week of September 28, 2026

Our first Hezbollah Financial Statements report finds the organization acquired $157 million in weapons during 2024, with Iran supplying roughly $129 million as an in-kind grant and Hezbollah spending the remaining $28 million in cash on its own procurement. The Jerusalem Post and Fox News both carried the figures this week.

The split is the finding, not the total. An in-kind grant and a cash purchase are different vulnerabilities: the first depends on a supply route that can be interdicted, the second on money that has to move through something resembling a financial system. Set against the wider picture, Hezbollah’s criminal, social and political enterprises generate a significant portion of its overall budget, and the rest comes from Iran as its main state patron. Expect more memos analyzing Hezbollah’s financial activities in the coming weeks.

Treasury Names Two French Charities as Hamas Fundraising Fronts

U.S. TREASURY / OFAC  ·  October 2, 2026

OFAC designated Saleem Abdallah Saleem al-Zaq, a Gaza-based Al-Qassam Brigades battalion deputy who oversaw financial transfers, together with France-based fundraisers Faouzi Barika and Amel Oualid and the two charities they established, Association Baraka and Ensemble C Mieux. Treasury says the network collected more than $2 million between 2020 and 2026, including $1.5 million after the October 7, 2023 attack, moving it through cryptocurrency and money services businesses while presenting itself as humanitarian fundraising.

The charity channel endures because it is cheap to rebuild. A designated association re-registers under a new name with new signatories and the donor list follows, which is why naming one rarely closes the route. What makes this action different is the pairing of the Gaza-side financial officer with the European collection points, because the pipeline only works when both ends function. The figure worth sitting with is the $1.5 million raised after October 7, which indicates the fundraising did not merely survive the attack but accelerated on the strength of it.

Syria’s Central Bank Comes to New York, and Hezbollah Is Still on the Register

SANA / FDD / WILSON CENTER  ·  Week of September 28, 2026

A Central Bank of Syria delegation led by Governor Safwat Raslan met U.S. Treasury officials in New York to discuss rehabilitating the banking sector, restoring correspondent relationships, and reviewing an Oliver Wyman gap assessment. The talks follow the repeal of the Caesar Act in December 2025 and the rescission of Syria’s state sponsor of terrorism and HTS designations in August 2026.

Wilson Center analysis cautions that the reset is partial, since Syria remains on the FATF grey list and the Commercial Bank of Syria still carries a primary money-laundering-concern designation, so correspondent access stays constrained even as the sanctions architecture unwinds. The harder problem sits underneath the rehabilitation track rather than ahead of it. FDD research identifies eight Syria-based companies, including Al-Ahed Trade and Investment, with majority ownership or management ties to U.S.-sanctioned Hezbollah financiers Mohammad and Rashid al-Bazzal, which brings them inside OFAC’s 50 Percent Rule. Post-Assad Syria may be angling for reintegration, but on this evidence its financial sector still functions as a Hezbollah backyard, and no correspondent bank will miss that.

The UK Adds 31 Russia-Related Measures

UK GOVERNMENT  ·  Week of September 28, 2026

The United Kingdom designated 23 individuals and entities and imposed shipping sanctions on eight vessels, in a package of 31 measures targeting LNG shadow-fleet vessels, FSB officers and officials tied to civilian torture and child deportations, and pro-Kremlin disinformation networks.

Shadow-fleet designations are the part that touches this file. The same vessel-level evasion techniques that move Russian energy move Iranian oil, and the two programs increasingly name the same ship managers and the same flag registries. A vessel designation is cheap to impose and expensive to escape, because insurance and port access are harder to re-paper than corporate ownership.

About this brief. Terror Finance Weekly is compiled by CENTEF from open-source reporting and primary government releases for research and situational-awareness purposes. Items reflect developments published between September 28 and October 4, 2026. Allegations described in designation notices and indictments are the issuing authority’s findings and carry a presumption of innocence unless proven in court. Reporting is attributed to the outlets named; the judgments drawn from it are CENTEF’s own. Headlines link to source material where available.