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Financial Services Law Insights and Observations

OFAC sanctions Hizballah accountants and weapons facilitator

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

Financial Crimes

On December 1, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions pursuant to Executive Order 13224 against two individuals and two companies based in Lebanon for providing financial services to Hizballah. OFAC also designated another individual for actively working to procure weapons for Hizballah. According to OFAC, the designations target persons that manage and enable Hizballah’s financial operations throughout Lebanon, including Hizballah’s “quasi-financial institution” and its central finance unit. As a result, all property, and interests in property of the designated persons, “and of any entities that are owned, directly or indirectly, 50 percent or more by one or more blocked persons are also blocked.” OFAC regulations generally prohibit all transactions by U.S. persons or within the United States (including transactions transiting the United States) that involve any property or interests in property of designated persons. OFAC cautioned that “persons that engage in certain transactions with the persons designated today may themselves be exposed to sanctions or subject to an enforcement action.” Additionally, OFAC warned that a foreign financial institution that knowingly conducts or facilitates a significant transaction on behalf of any of the designated persons could be subject to U.S. sanctions.