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Financial Services Law Insights and Observations

OFAC sanctions additional Hizballah financiers

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

Financial Crimes

On January 21, the U.S. Treasury Department’s Office of Foreign Assets Control announced sanctions pursuant to Executive Order 13224 against a Hizballah-affiliated financial facilitator, along with members of an international network of facilitators and companies connected to both the designated individual and a Hizballah-linked financial facilitator sanctioned by OFAC on January 18 (covered by InfoBytes here). According to OFAC, the designated persons evaded sanctions efforts in order to help Hizballah gain access to the international financial system and raise funds to support acts of terrorism and other illicit activities. “Today’s action exposes and targets Hizballah’s misuse of the international financial system to raise and launder funds for its destabilizing activities as the Lebanese people suffer during an unprecedented economic crisis in Lebanon,” Under Secretary of the Treasury for Terrorism and Financial Intelligence Brian E. Nelson stated. “Treasury is committed to disrupting Hizballah’s illicit activity and attempts to evade sanctions through business networks while the group doubles down on corrupt patronage networks in Lebanon.”

As a result of the sanctions, all transactions by U.S. persons or in the U.S. that involve any property or interests in property of designated or otherwise blocked persons are generally prohibited. Additionally, “any entities that are owned, directly or indirectly 50 percent or more by them, individually, or with other blocked persons, that are in the United States or in the possession or control of U.S. persons, must be blocked and reported to OFAC.” U.S. persons are generally prohibited from engaging in any dealings involving the property or interests in property of blocked or designated persons, unless exempt or authorized by a general or specific OFAC license. OFAC further warned that the agency “can prohibit or impose strict conditions on the opening or maintaining in the United States of a correspondent account or a payable-through account of a foreign financial institution that knowingly conducted or facilitated any significant transaction on behalf of a Specially Designated Global Terrorist.”