IMRA Middle East News Updates

Weekly Commentary: Voluntary Liquidation of Hamas-Linked Assets in Turkey For Seed Money for Removal of Gaza Rubble

Thu, 11 Dec 2025 18:55:31 -0500

Weekly Commentary: Voluntary Liquidation of Hamas-Linked Assets in Turkey For Seed Money for Removal of Gaza Rubble
Dr. Aaron Lerner 11 December 2025

If Hamas and its allies are truly committed to building a peaceful Gaza then, along with relinquishing its arms in Gaza, Hamas should liquidate its assets overseas.

While Israel most certainly has every right to lay claim to these assets as partial compensation, the move would be more palatable for Hamas and its allies if the proceeds went towards funding the removal of rubble from Gaza.

The timeline below relates to all the Hamas assets in Turkey and shows ranges of time reflecting different assets.

It can be expected that a considerable sum of money could already be transferred within five months.

This would fit the schedule if the implementation of the rubble removing program is made contingent on the completion of the complete disarmament of Hamas and the other terror groups in Gaza.

This plan is to liquidate approximately US $200-300 million in Turkish-registered companies and real-estate holdings beneficially owned by Hamas or Hamas-designated individuals, and to transfer the net liquidation proceeds to an international escrow account (Boad of Peace–managed Gaza Reconstruction Trust), without:
- designating Hamas as a terrorist organization under Turkish law,
- invoking coercive seizure authorities (Law 6415 / Law 3713), or
- triggering adversarial criminal proceedings.

This plan relies entirely on voluntary civil/commercial procedures, consistent with the Turkish Commercial Code (TCC 6102), the Financial Crimes Law (5549), and the Foreign Direct Investment Law (4875), combined with one unavoidable political authorization for the final transfer.

The $250 million voluntarily liquidated from Hamas’s Turkish assets becomes the first-loss seed equity that allows the World Bank and Arab sponsors to issue a $1-1.5 billion Gaza Recovery Bond at investment-grade rates. For the first four to six years, debt service is securely covered by a pre-committed Gulf “solidarity top-up” ($80-120 million per year shared by the UAE, Saudi Arabia, and Qatar), a small earmarked Palestinian clearance revenue, and early rubble-processing proceeds - none of which requires new political decisions once the bond is signed. Beginning around year four, commercial recycling of Gaza’s 68 million tons of rubble generates $180-250 million annually at realistic throughput and market prices, fully replacing the Gulf top-up. Verified carbon credits from avoided CO₂ emissions add a further $40-60 million per year as a conservative cushion. In effect, Hamas’s Turkish assets de-risks the entire structure, limits Gulf involvement to a short and contractually locked bridge, and then lets Gaza’s own destroyed buildings pay private investors to clear themselves - with no further donor or taxpayer money required after the initial phase.

Here are details of the plan for the Hamas assets in Turkey:

I. Legal Mechanism
Core Legal Vehicle
Voluntary corporate dissolution under:
- TCC Arts. 529-548 (Joint-stock companies - A.Ş.)
- TCC Art. 643 (Limited-liability companies - Ltd. Şti., applying A.Ş. rules)
Regulatory Verification
Non-criminal AML/CFT review by MASAK under Law 5549 (information requests, compliance review).
International Outbound Transfer
Under FDI Law No. 4875, Art. 3, liquidation proceeds may be freely transferred abroad after tax, AML, and FX compliance, with political authorization required in high-visibility cases.

II. Step-by-Step Process

Step 1. Notarized dissolution resolution + liquidator appointment
Action: Hamas-controlled shareholders issue a notarized general assembly resolution approving voluntary dissolution and appointing liquidators (standard practice: at least one Turkish resident).
Responsible Institution: Notary Public → Trade Registry (MERSİS)
Legal Basis: TCC Arts. 529, 540
Realistic Timeline: 3-10 days

Step 2. Registration of dissolution + UBO disclosure to MASAK
Action: File resolution and liquidator details; provide full beneficial-ownership documentation to MASAK upon request for AML compliance.
Responsible Institution: Trade Registry + MASAK
Legal Basis: TCC Art. 540; Law 5549 Art. 17
Realistic Timeline: 1-3 weeks

Step 3. Creditor notifications in Trade Registry Gazette
Action: Three consecutive announcements (7 days apart) published in Türkiye Ticaret Sicili Gazetesi; statutory creditor objection period begins.
Under TCC 543,
- Known creditors receive a minimum 3-week call period.
- For unknown creditors, the one-year waiting period may be shortened only if the liquidator provides adequate security for potential claims, subject to court oversight.
Responsible Institution: Trade Registry Gazette
Legal Basis: TCC Art. 543
Realistic Timeline: Minimum 3 weeks (typically 4-6 weeks depending on creditor security requirements)

Step 4. Liquidation operations
Action: Liquidator prepares opening balance sheet, sells assets, settles legitimate debts, and fulfills tax obligations.
Responsible Institution: Liquidator (overseen by Trade Registry)
TCC Arts. 541-545
Realistic Timeline: 3-9 months (simple) / up to 12 months (real-estate heavy)

Step 5. Tax clearance certificate
Action: Revenue Administration confirms all corporate taxes, VAT, and withholding taxes paid.
Responsible Institution: Revenue Administration (GİB / Vergi Dairesi)
Legal Basis: Tax Procedure Law No. 213
Realistic Timeline: 2-6 weeks (parallel to Step 4)

Step 6. MASAK AML verification / no-objection
Action: Revised for accuracy:
MASAK reviews the liquidation transactions for AML/CFT compliance and raises no objections, allowing the liquidation to proceed to final distribution.
Responsible Institution: MASAK
Legal Basis: Law 5549 Art. 5; FATF Rec. 4
Realistic Timeline: 2-6 weeks

Step 7. Final general assembly + authorization of proceeds transfer
Action: Shareholders approve the closing balance sheet and authorize transfer of net proceeds to the Gaza Reconstruction Trust escrow account.
Responsible Institution: Notarized minutes → Trade Registry
Legal Basis: TCC Art. 547
Realistic Timeline: 1 week

Step 8. Presidential Decision / Cabinet instruction
Action: This step is political, not statutory, but is practically required for high-visibility transfers involving foreign entities.
The decision frames the transfer as “humanitarian assistance to Gaza” and ensures interagency alignment (Treasury, MASAK, MFA, TCMB, Trade Registry).
Published in Resmi Gazete, e.g.:
“Filistin’e İnsani Yardım Kapsamında Yapılacak Transferler Hakkında Karar.”
Responsible Institution: Presidency / Council of Ministers
Legal Basis: Administrative practice (2023-2025 precedent)
Realistic Timeline: 2–8 weeks

Step 9. Outward transfer processed
Action: Central Bank receives documentation for transfers above reporting thresholds; executes SWIFT payment to the UN/World Bank escrow.
Responsible Institution: Central Bank of Turkey (TCMB)
Legal Basis: FX Communiqué 2022-32/66
Realistic Timeline: 1-3 days

Step 10. Final deregistration
Action: Company removed from the commercial registry.
Responsible Institution: Trade Registry
Legal Basis: TCC Art. 548
Realistic Timeline:1 week

III. Realistic Total Timeline
- Best-case (simple portfolio, no objections): 5–7 months
- Normal case (real-estate holdings): 8–10 months
- Complex but cooperative: up to 12 months

IV. Key Advantages
- 100% civil/commercial - no terrorism designation required.
- No coercive seizure or freezing - fully voluntary and shareholder-driven.
- Creditor protections built-in (Registry Gazette announcements + security option).
- Liquidation proceeds qualify as “liquidation returns” → free transfer under FDI Law Art. 3 after compliance.
- Only one political step (Presidential Decision), easily framed domestically as humanitarian assistance.
- Entire process auditable by MASAK, the Court of Accounts (Sayıştay), and the international escrow trustee.

V. Conclusion
This plan is:
- statutorily accurate,
- procedurally compliant,
- politically realistic,
- defensible in Turkish courts,
- aligned with MASAK and Trade Registry practice, and
- operationally implementable within 5–12 months.

If Hamas signs the notarized dissolution resolutions tomorrow, the first funds could lawfully and transparently reach the Gaza Reconstruction Trust before the end of 2026-using Hamas’s own money to begin clearing Gaza’s rubble, without Turkey ever having to designate Hamas a terrorist organization.

This is the clean, fast, and practically politically viable path if there is a genuine transformation in Gaza.

________________________________________
IMRA - Independent Media Review and Analysis

Since 1992 providing news and analysis on the Middle East with a focus on Arab-Israeli relations

Website: www.imra.org.il

Weekly Commentary: Yes to Ending Funding - No To Disenfranchising Draft Dodgers

Fri, 05 Dec 2025 09:25:03 -0500

Weekly Commentary: Yes to Ending Funding - No To Disenfranchising Draft
Dodgers

Dr. Aaron Lerner Date: 5 December 2025

Some politicians have floated the idea that draft dodgers be denied the
right to vote.

It is a dangerous move against our democratic values.

There's more than enough to do to draft dodgers:

Draft dodgers should not get a discount on municipal taxes because they are
low income .

Draft dodgers should not get a discount on National Insurance and National
Health insurance because they are low income.

Draft dodgers should not have subsidized daycare for their kids.

Draft dodgers and the yeshiva they are recorded as attending shouldn't
receive government funds because they are studying at the yeshiva.

And more.

But, yes, even draft dodgers should have the right to vote.

________________________________________
IMRA - Independent Media Review and Analysis

Since 1992 providing news and analysis on the Middle East with a focus on
Arab-Israeli relations

Website: www.imra.org.il

Mend the Rifts - State Commission of Inquiry and Pull Draft Law

Sun, 30 Nov 2025 07:31:12 -0500

Mend the Rifts - State Commission of Inquiry and Pull Draft Law
Dr. Aaron Lerner 30 November 2025

"Faced with the security challenges and diplomatic opportunities now
standing before the State of Israel, I am committed to doing everything in
my power to mend the rifts, achieve unity among the people, and restore
trust in the institutions of the state."
Prime Minister Benjamin Netanyahu, 30.11.2025

Our Prime Minister is completely right.

And therefore, for that same purpose:

- A state commission of inquiry must be established, with its composition
determined by the President of the Supreme Court together with Justice
Solberg. I emphasize: "together" - not merely "in consultation."

- The Draft Law must be withdrawn. It is true that a rift may exist between
those who refuse to share the security and economic burden and those who are
willing to do so, but at this critical time the important thing is to
prevent a rift among those who are carrying the burden and are prepared to
defend the country.

________________________________________
IMRA - Independent Media Review and Analysis

Since 1992 providing news and analysis on the Middle East with a focus on
Arab-Israeli relations

Website: www.imra.org.il

Weekly Commentary: Enable Security Personnel To Warn Political Echelon

Wed, 26 Nov 2025 10:29:43 -0500

Weekly Commentary: Urgent Legislation So Security Personnel Can Warn
Political Echelon
Dr. Aaron Lerner 26 November 2025

Fact: Numerous Israeli security personnel warned their superiors of the
impending October 2023 disaster, but these warnings never reached the
political echelon.

The security echelon already has a set-up which allows for anyone in the
security echelon to jump the chain of command to provide critical
information to the head of their organization.

But today, already two years after the October 2023 disaster, it is
literally a violation of the law for members of the security echelon to
communicate with the political echelon without authorization from the top of
their chain of command.

We urgently need to extend this arrangement to its logical conclusion: a
set-up which allows for anyone in the security echelon to jump the chain of
command to provide critical information to the heads of the political
echelon, the Minister of Defense, and the Prime Minister.

Some have warned that such an arrangement would overwhelm the DM and PM
messages from "nudniks" in the security echelon.

But the arrangement doesn't need to give those who send the DM or PM reports
and warnings the protection enjoyed by whistle blowers.

In fact, the arrangement could require that a copy of any such communication
much also be sent, at the same time, to their immediate superior.

Those choosing to jump the chain of command would be literally betting their
careers on the importance of the information they are sharing.

From what we know today of the frustration of the lower echelons dealing
with "Jericho Wall", the spotters and others, It made sense that these same
people didn't contact the top of their own security groups because they knew
that the security echelon was blinded by the "conception".

It is reasonable, however, to conclude that they would have reached out to
Netanyahu if there was a way to do it, knowing that if there was a record
that the information was brought to his attention that Netanyahu, ever
fearful of future commissions of enquiry, would have acted on it.

It is with a heavy heart that I note that even in the national camp there
are many who vociferously oppose making it possible for people in the
security echelon to jump the chain of command to reach the PM and DM with
critical information.

For the life of me I don't know why so many good Israelis are unable to
connect the dots.

There is legislation stuck in the Knesset addressing this issue.

Even a dog who gets hit by a car learns not to go into the street again.

We urgently need to learn our lesson.

________________________________________
IMRA - Independent Media Review and Analysis

Since 1992 providing news and analysis on the Middle East with a focus on
Arab-Israeli relations

Website: www.imra.org.il

Saudi Timeline To Pal Statehood Could Undermine What We Already Have

Thu, 20 Nov 2025 14:22:35 -0500

Observation: Saudi Timeline To Pal Statehood Could Undermine What We Already
Have
Dr. Aaron Lerner 20 November 2025

As I write this there's a convoy of cargo trucks on the way from the Gulf
through Saudi Arabia to Israel in a commercial operation for hot cargo too
heavy to fly.

Civilian jets are also flying over Saudi airspace on their way between
Israel and many destinations.

Behind the scenes there's considerable commerce underway between the two
countries.

And I'm not going to go into other active collaboration.

All of this is without any timeline for a sovereign Palestinian state.

Now some talking heads are suggesting that not such a big deal for there to
be yet another timeline for a Palestinian state.

This time one which is tied to the Saudis.

We've ultimately dodged the bullet with other timelines.

So, indeed, what's the big deal.

Well, I think it is important that convoys of cargo trucks and civilian jets
pass through Saudi Arabia one their way between Israel and other places in
the world.

I think it's important that there's considerable commerce.

And that active collaboration is certainly important.

But if there's a formal timeline for a sovereign Palestinian State and it is
associated with the Saudis there's a good chance that when that timeline
isn't met that the Saudis, due to domestic, regional and even worldwide
pressure, find themselves compelled to not only drop whatever additional
advancements there were in our relations, but also all of the things I've
mentioned above which we had without a timeline.

No timetables please.

Not even one with milestones whose fulfillment we can debate.

For anything we might temporarily gain by a timeline for a sovereign
Palestinian state. we have magnitudes more to lose at the end of it.

________________________________________
IMRA - Independent Media Review and Analysis

Since 1992 providing news and analysis on the Middle East with a focus on
Arab-Israeli relations

Website: www.imra.org.il

For free regular subscription:
Subscribe at no charge: imra-subscribe@imra.org.il
Unsubscribe: imra-unsubscribe@imra.org.il

For free daily digest subscription:
Subscribe at no charge: imra-subscribe-digest@imra.org.il
Unsubscribe: imra-unsubscribe@imra.org.il

IMRA is now also on Twitter
http://twitter.com/IMRA_UPDATES

Weekly Commentary: Israel Needs Crash Program To Defend Against Stealth Platforms

Thu, 20 Nov 2025 09:43:08 -0500

Weekly Commentary: Israel Needs Crash Program To Defend Against Stealth
Platforms
Dr. Aaron Lerner 20 November 2025

With China, Russia and the Turks all planning to supply stealth platforms to
our region, Israel needs a crash program to defend against this technology.

President Trump's announcement of plans to sell F-35's to the Saudis simply
offers an opportunity for the issue to reach towards to the top of the high
stack of challenges our decision makers must contend with.

We already have many of the tools for a comprehensive stealth detection
system and the sophisticated military industry needed to complete the puzzle
in-house.

I emphasize "in-house" because we cannot risk including critical foreign
made parts in the system.

Ideally our crash program might be a two-track program: one based on
conventional solutions with certain success and the other pursuing a
promising exotic approach which, if successful, promises significant
advantages over conventional systems.

The above applies to detecting stealth platforms, neutralizing what the
platforms launch and intercepting the platforms themselves.

This is anything but a cheap overnight program.

But the question isn't if Iran, Egypt, Saudi Arabia and basically everyone
else in the region is going to ultimately have stealth platforms. It is
when.

It is critical that we implement an in-house crash program to address this
challenge before it is too late.
.
________________________________________
IMRA - Independent Media Review and Analysis

Since 1992 providing news and analysis on the Middle East with a focus on
Arab-Israeli relations

Website: www.imra.org.il