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OFAC sanctions Hizballah financiers in Lebanon
On January 18, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions pursuant to Executive Order 13224 against three Hizballah-linked financial facilitators and their Lebanon-based travel company. According to OFAC, “Hizballah’s widespread network of financial facilitators has helped the group exploit Lebanon’s financial resources and survive the current economic crisis.” The designated persons allow Hizballah “access to material and financial support through the legitimate commercial sector to fund its acts of terrorism and attempts to destabilize Lebanon’s political institutions,” OFAC stated, adding that the sanctions demonstrate the agency’s “ongoing efforts to target Hizballah’s continued attempts to exploit the global financial sector and evade sanctions.” 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 by a foreign financial institution that either knowingly conducted or facilitated any significant transaction on behalf of a Specially Designated Global Terrorist,” or “knowingly facilitates a significant transaction for Hizballah or certain persons designated for their connection to Hizballah.”
OFAC sanctions individual and entity connected to international terrorism
On September 29, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions in coordinated efforts with the Government of Qatar, pursuant to Executive Order 13224, as amended, against seven individuals and one entity connected to a major Hizballah financial network based in the Arabian Peninsula. According to OFAC, three of the individuals are designated as Specially Designated Global Terrorists (SDGTs) “for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, Hizballah.” Four additional individuals have been designated as SDGTs “for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of,” one of the three individuals designated as SDGTs above. One entity is also being designated “for being owned, controlled, or directed by, directly or indirectly,” one of the individuals designated as SDGTs. As a result, all property and interests in property belonging to the designated persons subject to U.S. jurisdiction are blocked, and 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.” OFAC 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 by a foreign financial institution that either knowingly conducts or facilitates any significant transactions on behalf of a SGDT, or that, among other things, knowingly facilitates a significant transaction for Hizballah or certain persons designated for their connection to Hizballah.” OFAC’s announcement further noted that that “[e]ngaging in certain transactions with the individuals and entity designated today entails risk of secondary sanctions pursuant to E.O. 13224, as amended.”
OFAC sanctions entities connected to international terrorism
On September 17, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions pursuant to Executive Order 13224 against members of Lebanon- and Kuwait-based financial conduits that fund Hizballah. In addition, OFAC designated members of an international network of financial facilitators and front companies connected to Hizballah and Iran’s Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF). Together, these networks allegedly “laundered tens of millions of dollars through regional financial systems and conducted currency exchanges and trades” for the benefit of both entities. According to OFAC, Hizballah, supported by the IRGC-QF, utilized the revenues from these networks to fund terrorism, and condoned instability throughout the region. As a result, all property and interests in property belonging to the designated persons subject to U.S. jurisdiction are blocked, and 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 control of a U.S. person must be blocked.” U.S. persons are “generally prohibited from engaging in transactions” with the designated members. 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 by a foreign financial institution that either knowingly conducted or facilitated any significant transaction on behalf of a Specially Designated Global Terrorist or, among other things, knowingly facilitates a significant transaction for Hizballah or certain persons designated for their connection to Hizballah.”
OFAC sanctions Hizballah finance official and Lebanese shadow bankers
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.”
OFAC sanctions entities for Iranian petrochemical sales
On October 29, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions pursuant to Executive Order 13846 against eight entities for their alleged “involvement in the sale and purchase of Iranian petrochemical products brokered by [a petrochemical company]. . .designated by Treasury in January 2020.” The designated entities—based in Iran, China, and Singapore—allegedly aided the petrochemical company’s efforts to process and move funds generated by the sale of these products, which were then used to finance the Iranian regime’s “destabilizing agenda of support to corrupt regimes and terrorist groups throughout the Middle East and, more recently, Venezuela.”
In addition, OFAC also updated its List of Specially Designated Nationals and Blocked Persons to add additional aliases for an Iraq-based bank that was previously designated, among other things, for being “used by Iran’s Central Bank Governor to covertly funnel millions of dollars on behalf of the IRGC-QF to support Hizballah.”
As a result, all property and interests in property belonging to, or owned by, the designated persons subject to U.S. jurisdiction are blocked, and U.S. persons are also “generally prohibited from engaging in transactions with them.” OFAC further warned foreign financial institutions that knowingly facilitating significant transactions or providing significant support to the designated persons may subject them to sanctions that terminate their access to the U.S. financial system.
OFAC sanctions Hizballah council members
On October 22, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions pursuant to Executive Order (E.O.) 13224 against two members of Hizballah’s Central Council, which supports Hizballah’s activities by identifying and electing council members that assert control over policies and military initiatives. As a result of the sanctions, all property and interests in property of the individuals, “and of 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, are blocked and must be reported to OFAC.” OFAC noted that its regulations “generally prohibit” U.S. persons from participating in transactions with the designated individuals, including “the making of any contribution of funds, goods, or services by, to, or for the benefit of any blocked person or the receipt of any contribution of funds, goods or services from any such person.” OFAC further warned that engaging in certain transactions with the designated individuals subjects persons to the risk of secondary sanctions pursuant to E.O. 13224 and the Hizballah Financial Sanctions Regulations, which implement the Hizballah International Financing Prevention Act of 2015. Furthermore, OFAC noted that it has the authority to “prohibit or impose strict conditions on the opening or maintaining in the United States of a correspondent account or a payable-through account by a foreign financial institution that knowingly facilitates a significant transaction for Hizballah or on behalf of a designated terrorist group, or a person acting on behalf of or at the direction of, or owned or controlled by, Hizballah.”
OFAC sanctions Hizballah-associated Lebanon-based companies
On September 17, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions pursuant to Executive Order 13224 against two Lebanon-based companies for being owned, controlled, or directed by Hizballah. According to OFAC, the two companies are leveraged by Hizballah “to conceal money transfers to Hizballah’s own accounts,” which “further enrich[es] Hizballah’s leadership and supporters, and depriv[es] the Lebanese people of much-needed funds.” These sanctions are part of Treasury’s continuing efforts to disrupt the full range of Hizballah’s illicit financial activity. Since 2017, OFAC has designated more than 90 Hizballah-affiliated individuals and entities. As a result of the sanctions, all property and interests in property of the individuals, “and of 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, are blocked and must be reported to OFAC.” OFAC noted that its regulations “generally prohibit” U.S. persons from participating in transactions with the designated individuals, including “the making of any contribution or provision of funds, goods, or services by, to, or for the benefit of any blocked person or the receipt of any contribution or provision of funds, goods or services from any such person.” OFAC further warned that engaging in certain transactions with the designated individuals subjects persons to the risk of secondary sanctions pursuant to E.O. 13224 and the Hizballah Financial Sanctions Regulations, which implement the Hizballah International Financing Prevention Act of 2015. Furthermore, OFAC noted that it has the authority to “prohibit or impose strict conditions on the opening or maintaining in the United States of a correspondent account or a payable-through account by a foreign financial institution that knowingly facilitates a significant transaction for a terrorist group like Hizballah, or a person acting on behalf of or at the direction of, or owned or controlled by, [a Specially Designated Global Terrorist] such as Hizballah.”
OFAC sanctions Hizballah-associated former Lebanese ministers
On September 8, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions pursuant to Executive Order (E.O.) 13224 against two former Lebanese government ministers who allegedly “provided material support to Hizballah and engaged in corruption.” According to OFAC, the sanctions are part of Treasury’s continuing effort to “prioritize disruption of the full range of Hizballah’s illicit financial activity,” which has designated over 90 Hizballah-affiliated persons since 2017. As a result of the sanctions, all property and interests in property of the individuals, “and of 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, are blocked and must be reported to OFAC.” OFAC noted that its regulations “generally prohibit” U.S. persons from participating in transactions with the designated individuals, including “the making of any contribution or provision of funds, goods, or services by, to, or for the benefit of any blocked person or the receipt of any contribution or provision of funds, goods or services from any such person.” OFAC further warned that engaging in certain transactions with the designated individuals subjects persons to the risk of secondary sanctions pursuant to E.O. 13224 and the Hizballah Financial Sanctions Regulations, which implement the Hizballah International Financing Prevention Act of 2015. Furthermore, OFAC noted that it has the authority to “prohibit or impose strict conditions on the opening or maintaining in the United States of a correspondent account or a payable-through account by a foreign financial institution that knowingly facilitates a significant transaction for a terrorist group like Hizballah, or a person acting on behalf of or at the direction of, or owned or controlled by, [a Specially Designated Global Terrorist] such as Hizballah.”
OFAC designates Hizballah-associated companies and officials as global terrorists
On February 26, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) designated three individuals and 12 entities—all based in Lebanon—as Specially Designated Global Terrorists (SDGTs). Pursuant to Executive Order 13224, as amended, OFAC designated two of the individuals as leaders or officials of a Hizballah-related foundation that was previously designated for supporting terrorism in 2007. The entities are also associated with the foundation. One of the entities controlled by the foundation and a number of its subsidiaries reportedly did business with a Lebanon-based bank, which had been designated as an SDGT in August, allowing Hizballah to avoid close examination of its transactions by Lebanese banking authorities.
OFAC reiterated that “all property and interests in property of these targets that are in the United States or in the possession or control of U.S. persons must be blocked and reported to OFAC. OFAC’s regulations generally prohibit all dealings by U.S. persons or within the United States (including transactions transiting the United States) that involve any property or interests in property of blocked or designated persons. In addition, persons that engage in certain transactions with the individuals and entities designated today may themselves be exposed to sanctions or subject to an enforcement action.”
OFAC designates Lebanon and DRC-based Hizballah money launderers
On December 13, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions pursuant to Executive Order 13224 against two Lebanon- and Democratic Republic of the Congo (DRC)-based money launderers and their affiliated companies for allegedly generating tens of millions of dollars for Hizballah, its financiers, and their activities. According to OFAC, the sanctions are part of Treasury’s continued prioritization to disrupt “the full range of Hizballah’s illicit financial activity,” which has, to date, designated 80 Hizballah-affiliated persons since 2017. As a result of the sanctions, “all property and interests in property of these targets that are in the United States or in the possession or control of U.S. persons must be blocked and reported to OFAC.” OFAC notes that its regulations “generally prohibit” U.S. persons from participating in transactions with the designated persons, and states that persons who engage in certain transaction with the designated individuals and entities “may themselves be exposed to sanctions or subject to an enforcement action.” The designated persons are also subject to secondary sanctions pursuant to the Hizballah Financial Sanctions Regulations, which implement the Hizballah International Financing Prevention Act of 2015, and allow OFAC the authority to “prohibit or impose strict conditions on the opening or maintaining in the United States of a correspondent account or a payable-through account by a foreign financial institution that knowingly facilitates a significant transaction for a terrorist group like Hizballah, or a person acting on behalf of or at the direction of, or owned or controlled by, [a Specially Designated Global Terrorist] such as Hizballah.”
OFAC also issued three new counter terrorism-related FAQs, which provide additional guidance related to the designated persons.