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Financial Services Law Insights and Observations

OFAC sanctions Hizballah finance official and Lebanese shadow bankers

Financial Crimes OFAC Department of Treasury Sanctions OFAC Designations SDN List Of Interest to Non-US Persons Lebanon

Financial Crimes

On May 11, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions pursuant to Executive Order 13224 against seven individuals in connection with Hizballah and its financial firm, which is used by Hizballah to direct the terrorist organization’s financial involvements and to access the international financial system. According to OFAC, one of the sanctioned individuals, who serves as the Chief of Hizballah’s Central Finance Unit, has “acted or purported to act for or on behalf of, directly or indirectly, Hizballah.” The other sanctioned individuals have “acted or purported to act for or on behalf of, directly or indirectly, [the financial firm].” As a result of the sanctions, all property and interests in property belonging to the sanctioned persons, and “any entities that are owned, directly or indirectly, 50 percent or more” by them that are subject to U.S. jurisdiction are blocked and must be reported to OFAC. OFAC notes that its regulations generally prohibit U.S. persons from participating in transactions with these persons, which include “any property or interests in property of designated or otherwise blocked persons.”

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