Attacks on aid convoys traveling through the West Bank eligible for sanctions under U.S. executive order against those responsible for violence in West Bank
(Washington, D.C., June 10, 2024) — The U.S. Departments of State and Treasury should impose sanctions on individuals associated with "Tzav 9," a violent group blocking critical humanitarian aid en route to civilians in the Gaza Strip, as well as the Israeli entities fundraising for them, including Israeli nonprofit organization "Torat Halechima" and Israeli company TickChak (GiveChak). Additionally, the Treasury Department should investigate US-based NGO JGIVE-Friends of Asor Fund USA Inc and payment processor Stripe for facilitating donations to the group's unlawful, violent activities.
"Tzav 9's violent attacks to block humanitarian aid for Gaza could not take place without the well-oiled network of companies and organizations funding and supporting them," said Michael Schaeffer Omer-Man, director of research for Israel-Palestine at DAWN. "If the U.S. is serious about punishing all of those responsible for this kind of criminal activity, it should sanction companies like TickChak, which has repeatedly financed violent settlers, including their attacks on humanitarian aid convoys."
Tzav 9 attacks in the West Bank, and the companies and organizations helping it fund these attacks, meet all of the criteria for financial and other sanctions under Executive Order 14115, which targets foreign persons and entities responsible for directing, planning, and participating in property destruction, the seizure or dispossession of property by private actors, acts of violence, and other actions that threaten the peace, security, or stability of the West Bank. Since February 1, 2024, the U.S. has sanctioned 12 violent Israelis and supporting entities under this order, as well as one Palestinian militant group.
Tzav 9 Attacks on Humanitarian Aid Convoys
On May 15, 2024, DAWN sent the State Department a dossier documenting how the group Tzav 9, whose name refers to call-up orders the Israeli military issues to reserve soldiers, has organized, planned, and facilitated violent attacks to physically block, plunder, and destroy humanitarian aid intended for Palestinian civilians in the Gaza Strip, and relied on Israeli companies and Israeli and American non-profit organizations to fundraise for its violent attacks. As documented by DAWN, at least since January 2024, the group has recruited individuals to participate in the aid-destruction attacks, coordinated logistics such as arranging for and paying for transportation to the attacks. Israeli and international media outlets have documented Tzav 9-organized violent aid-blocking attacks that took place in February, March, April, and May of 2024, and DAWN independently verified Tzav 9's role in at least half of those attacks.
Tzav 9 and its supporters openly and specifically targeted for interception and destruction, humanitarian aid and supplies that were meant for civilians in the Gaza Strip, where USAID Administrator Samantha Power has said there was famine as early as April 10, 2024. On one of its crowdfunding campaigns reviewed and documented by DAWN, Tzav 9 explicitly stated that denying civilians critical humanitarian aid was its goal, writing, "Supplies and humanitarian aid for Gazan civilians must be withheld until our hostages receive medicines, food and Red Cross visitation." In its channel on the Telegram messaging site, it explained, "All of the donations to Tzav 9 go directly to public relations, logistical equipment, legal counsel, promotions, transportation, and everything that can help us shut off Hamas's oxygen line."
"The impunity these vigilantes have enjoyed from Israeli authorities plays an undeniable role in their shocking acts of violence intended to starve Palestinians," said Sarah Leah Whitson, executive director of DAWN. "Their efforts to block critical humanitarian aid has directly contributed to the creation of famine and starvation in the Gaza Strip."
On numerous occasions, the group has organized multiple attacks on humanitarian aid convoys in different locations at the same time, publishing each location on separate WhatsApp groups and arranging and coordinating logistics. Their posts often include direct calls, which DAWN has documented, to action asking supporters to donate funds for the attacks and provide links to the two fundraising campaigns where donations can be made. Since the start of 2024, Tzav 9 has planned and carried out many of its attacks in the occupied West Bank, including violent mob assaults on Palestinian truck drivers, as the Association for Civil Rights in Israel recently documented. Israeli authorities have taken very little action to stop or prosecute these vigilante attackers.
Companies and Groups Fundraising for Tzav 9 Violent Attacks
DAWN's investigation details how two Israeli entities and one American nonprofit organization ran the crowdfunding campaigns for Tzav 9's humanitarian aid-blocking efforts. Israeli NGO "Torat Halechima," loosely translated from Hebrew as "Combat Doctrine," is an Israeli-registered nonprofit organization that was listed as the initiator and owner of the crowdfunding campaign for Tzav 9 on the GiveChak crowdfunding website. As of May 15, 2024, that campaign had raised $128,296 on behalf of Tzav 9. The Asor Fund and JGIVE-Friends of Asor Fund USA Inc (nonprofit organizations registered in Israel and the U.S, respectively) own and operate JGive.com, an Israeli donor-advised fund that accepts donations on behalf of Israeli charities and directs those donations to them. JGive.com accepted both U.S. dollar and new Israeli shekel donations for the Tzav 9 attacks and as of May 15, 2024, had raised $87,858 for it. Both campaigns, on GiveChak and JGive, were explicit about their purpose: to fund direct actions to block humanitarian aid for Gaza.
"Sanctioning Israeli settlers involved in attacks on humanitarian aid to Gaza is an important first step, but these settlers are not lone wolves," said Raed Jarrar, DAWN's advocacy director. "The U.S. government should also sanction the Israeli organizations and companies behind these violent Israeli extremists."
On May 13, 2024, U.S. National Security Advisor Jake Sullivan told reporters:
It is a total outrage that there are people who are attacking and looting these convoys coming from Jordan going to Gaza to deliver humanitarian assistance. We are looking at the tools that we have to respond to this. And we are also raising our concerns at the highest level of the Israeli government, and it's something that we make no bones about. This is completely and utterly unacceptable behavior.
Funding and facilitating attacks in the West Bank on aid convoys should be considered within the scope of the Executive Order 14115, which allows the State and Treasury Departments to sanction groups, individuals, entities, and officials found to be "to be responsible for or complicit in, or to have directly or indirectly engaged or attempted to engage in," among other acts: "actions — including directing, enacting, implementing, enforcing, or failing to enforce policies — that threaten the peace, security, or stability of the West Bank"; "planning, ordering, otherwise directing, or participating in […] an act of violence or threat of violence targeting civilians […] property destruction or […] seizure or dispossession of property by private actors." The Treasury Department previously sanctioned the Har Hebron Fund for similar financial support for sanctionable activities. The United States government also should consider other avenues for holding entities accountable for such actions, including civil actions and different sanctions programs.
Finally, the U.S, should investigate U.S. companies and charities facilitating donations for criminal activities by Israeli groups, including Tzav 9. The Internal Revenue Service requires all U.S. non-profits to ensure that its assets are used for charitable purposes, and can revoke charity status if a non-profit makes grants to foreign organizations and it cannot demonstrate that the grants were actually used for exempt purposes, which are limited to "charitable, religious, educational, scientific, literary, testing for public safety, fostering national or international amateur sports competition, and preventing cruelty to children or animals."
The following companies and organizations have directly supported Tzav 9 in fundraising for the attacks on critical humanitarian assistance to Palestinians experiencing a man-made famine in the Gaza Strip:
- Torat Halechima
"Torat Halechima," loosely translated from Hebrew as "Combat Doctrine," is an Israeli-registered nonprofit organization (Israeli registered association #: 580661460) that was hosted on the GiveChak crowdfunding website as the initiator and owner of the crowdfunding campaign for Tzav 9. As of May 15, 2024, the campaign had raised $128,296 on behalf of Tzav 9. Founded in 2018, in 2022 the organization had three employees and an operating budget of roughly $125,000. Its website describes its work as strengthening the Jewish identity of the Israeli army and fighting the influence of "radical leftist" values and agendas. "We are exerting great efforts, together with civilians, commanders and reservist soldiers, to preserve the IDF as a victorious Jewish army," its website states. The organization's two listed board members are Michael Ariye Shag and Meir Goldmintz.
- GiveChak.co.il (subsidiary of TickChak)
GiveChak has served to facilitate funding for Tzav 9's violent attacks on aid convoys by hosting fundraising campaigns on its website and has close ties to Israeli settler groups, repeatedly assisting them in evading U.S. sanctions. The company is a wholly owned subsidiary of private Israeli company TickChak Ltd. (Israeli company ID#: 515676294), whose primary business is as an events ticketing platform; it operates the GiveChak website to host and facilitate crowdfunding campaigns. TickChak has close ties to settler activists, including the Yesha Council, the primary association of Israeli settlements in the West Bank and formerly in the Gaza Strip, was founded in 2017. Before co-founding TickChak, Chief Technology Officer Eliyahu Baratz worked for Yesh Shachar Productions, Ltd., a private company that is a subsidiary of the Yesha Council. One of Yesh Shachar's three owners, Shirel Shlomo Bleicher, is a shareholder of TickChak and a project manager at the Yesha Council. Its second owner, Ita Diller, is an officer of the Yesha Council's non-profit organization, Israeli Registration #: 580186492); and the third is the Yesha Council itself. Baratz is also listed as the administrative contact on the Yesha Council website's domain registration. In some TickChak corporate documents and on some webpages on GiveChak, the personal cellular phone number of Bleicher, the Yesha Council projects manager, is listed as the company's point of contact.
GiveChak previously hosted crowdfunding campaigns (here and here) openly evading U.S. sanctions on violent Israeli settlers Moshe Sharvit and Yinon Levi, which together raised over $1 million. GiveChak is currently hosting campaigns for projects to build and expand illegal Israeli settlements in the occupied West Bank, including several explicitly supporting so-called "outpost" farms linked to violence against—and the expulsion of—Palestinian civilians. TickChak's website lists Israeli universities, newspapers, municipalities, a government ministry, and the Israeli parliament, the Knesset, as clients. Israel's Bank HaPoalim, whose online payment app Bit has processed donations to all of the sanctions-related fundraisers, is also listed as a client on TickChak's website.
- The Asor Fund and JGive.com
The Asor Fund (Israeli registered association #: 580586998) and JGIVE-Friends of Asor Fund USA Inc (US-registered charity EIN: 81-0757923) own and operate JGive.com, an Israeli donor-advised fund that accepts donations on behalf of Israeli charities and directs those donations to them. DAWN documented in its investigation how JGive.com accepted both U.S. dollar and new Israeli shekel donations for the Tzav 9 campaign, although it appears now to have removed both the English- and Hebrew-language crowdfunding pages.
Both organizations share an executive director, Ori Ben Shlomo. Founded in 2014, the Asor Fund's annual income for 2022 was reported as ILS 135,692,601 (roughly $32 million). JGive.com's reported income for 2022 was $26 million.
- Bit (Bank HaPoalim)
Bit, the wholly owned and operated payment app of Israel's Bank HaPoalim (Israeli private company #: 520000118), has processed donations to the Tzav 9 campaign (owned by Torat Halechima) on GiveChak. The Bit payment app, an Israeli service akin to Venmo or Zelle, is one of two default payment options for campaigns on GiveChak.
It also has processed donations to several other campaigns to evade US sanctions placed on violent Israeli settlers, as DAWN documented and submitted to relevant US government agencies. Following DAWN'S March 22, 2024 report, GiveChak removed Bit as a payment option from a campaign to raise funds for Moshe Sharvit and his settlement outpost, Moshe's Farm, even though the campaign itself remained online. Bank Hapoalim owns and operates numerous branches and investment companies and securities brokers in the United States, according to its filings with the Federal Reserve.
- Pelecard
Pelecard (Pelecard Finance, Ltd., Israeli private company registration #: 516667136) has processed donations to the Tzav 9 campaign on GiveChak, according to DAWN's investigation. Pelecard previously processed donations to a sanctions evasion campaign by the Har Hebron Fund for sanctioned violent settler Yinon Levi, as documented and reported by DAWN.
- Stripe
Stripe Payments Company, (Stripe, Inc., LEI #: 549300YK0Z4SWKNYPQ72). a multinational financial services company dual-headquartered in South San Francisco, California, United States and Dublin, Ireland, has processed U.S. dollar donations for the Tzav 9 campaign on JGive, DAWN's investigation found.
