An organization is banned or sanctioned, yet its personnel, projects and political work reappear under a different name. A new investigation by NGO Monitor documents several such cases. Particularly explosive: The pattern does not end at Israel’s borders. It leads to Brussels, Britain and Germany and raises the question of how much a sanction is worth when authorities and donors look only at an organization’s name.

Published on September 17, 2026, the NGO Monitor report examines organizations that are alleged to have continued their activities under new names, new legal entities or through branches in other states after bans, terrorist designations or sanctions. The Jüdische Allgemeine covered the investigation on September 18.

What NGO Monitor claims is not the only decisive factor. In several cases, central parts of the pattern described can be corroborated through government documents, sanctions lists, registry information and statements by the organizations involved themselves.

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Masar Badil: US sanctions link the organization to Samidoun

The clearest case concerns Samidoun and Masar Badil. The Samidoun Palestinian Prisoner Solidarity Network was banned in Germany on November 2, 2023. The United States and Canada imposed sanctions on the organization in 2024. Washington describes Samidoun as a fundraising organization for the Popular Front for the Liberation of Palestine, PFLP.

On August 26, 2026, the US Treasury Department went a step further. The US sanctions authority OFAC added Masar Badil to the American sanctions list and explicitly linked the organization to Samidoun. Two Masar Badil officials, Zaid Abdulnasser and Rawa Alsagheer, were also sanctioned. In the OFAC data, Masar Badil is listed directly as connected to Samidoun. The US Treasury Department also expressly describes Masar Badil as a front for the PFLP and as a front for Samidoun. The organizational connection is therefore no longer merely a claim by NGO Monitor.

This matters because Masar Badil has existed since 2021. The organization was therefore not founded only after the later sanctions against Samidoun. The crucial point is a different one: According to the US government’s finding, Masar Badil and Samidoun share, among other things, leadership personnel and financing mechanisms. Masar Badil was therefore sanctioned on the basis of its connection to Samidoun.

The relationship between Samidoun and Masar Badil is no longer merely a matter of NGO Monitor’s interpretation. In August 2026, the US Treasury Department itself sanctioned Masar Badil, officially linked it to Samidoun and expressly described it as a front for the PFLP.

NGO Monitor investigation: Direct Action Training after the ban

NGO Monitor describes a similar problem in Britain. Palestine Action was banned as a terrorist organization under the UK Terrorism Act in July 2025. In August 2026, the United States also imposed sanctions on the organization.

An investigation by NGO Monitor now points to an initiative called Direct Action Training, or DAT. It emerged in the immediate temporal context of the British ban and likewise promotes direct action against companies with links to Israel. NGO Monitor points to similar language and forms of action, as well as to the fact that Palestine Action co-founder Huda Ammori publicly called on people to look into Direct Action Training.

Here, the evidence differs clearly from the Masar Badil case. Neither the British nor the American government has so far officially classified DAT as a successor or front organization of Palestine Action. NGO Monitor assesses DAT as a possible circumvention structure. There has been no official finding to that effect. This illustrates precisely how difficult sanctions become when a banned legal entity disappears, but activists, forms of action and political objectives reappear in other structures.

UAWC and Al-Ard: Links, the state of the dispute and German responses

For Germany, the report is particularly interesting when it comes to the relationship between the Union of Agricultural Work Committees, UAWC, and Al-Ard for Agricultural Development.

In 2021, Israel designated UAWC, along with five other Palestinian organizations, as a terrorist organization and justified this with links to the PFLP. European governments did not adopt this designation at the time. In July 2022, Germany, Belgium, Denmark, France, Ireland, Italy, the Netherlands, Spain and Sweden jointly stated that the information presented to them was, in their view, insufficient to change their policies toward the six organizations. This position of the Federal Foreign Office is part of the dispute.

But that is not where the story ends. The investigation by Proximities commissioned by the Dutch government identified a total of 34 people with individual links between UAWC and the PFLP for the period from 2007 to 2020. According to the investigation, 28 of these 34 people sat on UAWC’s board. In twelve cases, dual mandates existed temporarily: The individuals simultaneously held a leadership position at UAWC and a role in the PFLP environment. Seven of them were active in the PFLP’s political wing, while five worked in organizations that Proximities attributed to an alleged civil-society wing of the PFLP.

At the same time, Proximities found no evidence of financial flows between UAWC and the PFLP, no organizational unity or control of UAWC by the PFLP, and no indications that UAWC employees or board members had used their positions at UAWC for terrorist activities or supported such activities. The Dutch government nevertheless ended its funding. In particular, it considered the large number of dual mandates among personnel and what it regarded as UAWC’s insufficient transparency toward its donors serious enough to take this step.

Funding practices were also restricted in Germany. In an answer by the German government from March 2024 it is initially expressly stated that the German government had made no direct payments to the six organizations. Project-related cooperation by German civil-society organizations funded by the Federal Ministry for Economic Cooperation and Development or the Federal Foreign Office had ended or was due to end shortly. Since October 2021 and until further notice, no foreign-policy clearance would be issued for new projects involving these six organizations.

And then Al-Ard appears.

An investigation by NGO Monitor documents personnel overlaps between UAWC and the organization Al-Ard, founded later. This does not automatically make Al-Ard UAWC under a new name. The relevant point is the documented continuity among personnel. According to NGO Monitor, Al-Ard’s chairman and director had previously been a UAWC board member and director, respectively. NGO Monitor also cites a report by the French organization Experts Solidaires, according to which Al-Ard acquired UAWC’s experience and expertise through the transfer of personnel, procedures and protocols.

What can be read without NGO Monitor is even more interesting: medico international currently lists two projects with Al-Ard for 2025: One concerns water and sanitation services as well as emergency aid in the Gaza Strip; the second supports small agricultural businesses in the Jordan Valley and the Nablus area.

For its Palestine and Israel projects in 2025, Medico reports a total of 1,995,010.56 euros and expressly notes that this also includes support from the Federal Ministry for Economic Cooperation and Development. The published breakdown does not show which individual partner was funded from which source of funds. It would therefore be wrong to claim that the two Al-Ard projects were demonstrably paid for with federal funds.

This is precisely where the oversight question arises: The German government denies foreign-policy clearance to new projects involving the six listed organizations. However, this rule does not automatically cover a new legal entity solely because former officials of a listed organization work there. At the same time, a German NGO, whose regional project funding also includes BMZ funds, is working with Al-Ard. The published project overview does not indicate whether or how such personnel continuities are taken into account in the specific funding review.

Al-Haq Europe Becomes Rights Matter: Name Change and New Legal Entities

The structure becomes even clearer in Brussels. Al-Haq is one of the six organizations that Israel designated in 2021 as terrorist organizations. In September 2025, the United States also imposed sanctions on Al-Haq. The American legal basis was different: The measures were taken under the US sanctions regime against the International Criminal Court and related to activities connected with ICC proceedings against Israeli nationals. The US sanction is therefore not an American finding supporting Israel’s PFLP designation.

What happened afterward in Belgium can at least be partially traced through registry data. According to an analysis of Belgian documents published by NGO Monitor on June 14, 2026 Al-Haq Europe changed its name to Rights Matter in June 2025. At the same time, its official objectives were changed and explicit references to Palestinians were removed from the statutes.

The name Al-Haq Europe did not disappear, however. In October 2025, an organization called Al-Haq Europe was registered again under a different registration number. According to NGO Monitor’s analysis, it took over Al-Haq Europe’s previous website and contact address.

The result was two legally distinct entities on paper: Rights Matter and a newly registered Al-Haq Europe. NGO Monitor documents personnel links between the structures, but itself describes their exact relationship as unclear. Whether the restructuring was expressly undertaken to circumvent American sanctions has not been officially established. What can be established with certainty are the name change, the new registration and the continuing personnel links.

Sanctions against legal entities do not automatically capture networks

The NGO Monitor report cites further examples. The evidence is not equally strong in every case. Not every new organisation is automatically a front organisation, and not every personnel overlap proves terrorist financing. Anyone claiming this is making things just as easy for themselves as those who ignore every continuity as soon as a new association name appears on the letterhead.

The real problem is more sober and larger: sanctions systems work with legal entities, account numbers, registrations and names. Political networks, by contrast, consist of people, relationships, donors, projects and infrastructure. If only the legal entity is examined, a network may continue to exist alongside it.

In the Samidoun complex, the United States has itself now sanctioned Masar Badil and leading officials and expressly named the organisational links. In the case of UAWC and Al-Ard, by contrast, the question is how European and German funding bodies assess documented personnel continuities. In the case of Al-Haq and the Belgian legal entities, it becomes clear how quickly an already complicated sanctions landscape can become even more opaque through name changes and additional registrations.

Sanctions are only as effective as the scrutiny behind them. Anyone who checks only whether a name appears on a ban or sanctions list is checking paperwork. What matters is whether personnel, leadership, funding channels and projects continue under a new legal entity.

The NGO Monitor report does not prove that every organisation examined is a front organisation. But it documents a real oversight problem that can be traced in several cases through government documents, registry data and organisations’ own statements. Where personnel, organisational or financial continuities are documented, they do not disappear through a new name. Anyone serious about sanctions must therefore examine networks, not just letterheads.