Today, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) is designating several individuals and associated entities for facilitating financial activities for Hizballah. At the center of this network is Lebanese money exchanger and so-called financial expert Hassan Moukalled, who plays a key role in enabling Hizballah to continue to exploit and exacerbate Lebanon’s economic crisis. Treasury is also designating CTEX Exchange, a money service business owned by Hassan Moukalled, in addition to Hassan Moukalled’s sons, Rayyan Moukalled and Rani Moukalled, who facilitate Hassan Moukalled and his company’s financial activities in support of Hizballah. As of mid-2022, Rani Moukalled and his brother Rayyan Moukalled were among several individuals authorized by their father, Hassan Moukalled, to engage in cash transactions on behalf of CTEX with the Central Bank of Lebanon. Rani is publicly associated with CTEX,
working as its manager. He is also an employee at LCIS.
Rayyan Moukalled is being designated for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, Hassan Moukalled, a person whose property and interests in property are blocked pursuant to E.O. 13224, as amended. Rani Moukalled is being designated for having acted or purported to act for or on behalf of, directly or indirectly, CTEX, a person whose property and interests in property are blocked pursuant to E.O. 13224, as amended.
On June 6, 2003, OFAC issued the Global Terrorism Sanctions Regulations, 31 CFR part 594 (68 FR 34196, June 6, 2003 (“the Regulations”), to implement Executive Order (E.O.) 13224 of September 23, 2001, “Blocking Property and Prohibiting Transactions With Persons Who Commit, Threaten To Commit, or Support Terrorism” (66 FR 49079, September 25, 2001). OFAC has amended the Regulations on several occasions.
On September 9, 2019, the President, invoking the authority of, inter alia, the International Emergency Economic Powers Act (50 U.S.C. 1701–1706) (IEEPA) and the United Nations Participation Act (22 U.S.C. 287c) (UNPA), issued E.O. 13886, “Modernizing Sanctions To Combat Terrorism” (84 FR 48041, September 12, 2019), effective September 10, 2019. In E.O. 13886, the President, finding it necessary to consolidate and enhance sanctions to combat acts of terrorism and threats of terrorism by foreign terrorists, terminated the national emergency declared in E.O. 12947 of January 23, 1995, “Prohibiting Transactions With Terrorists Who Threaten To Disrupt the Middle East Peace Process” (60 FR 5079, January 25, 1995), and revoked E.O. 12947, as amended by E.O. 13099 of August 20, 1998, “Prohibiting Transactions With Terrorists Who Threaten To Disrupt the Middle East Peace Process” (63 FR 45167, August 25, 1998). In addition, the President amended E.O. 13224, in order to build upon initial steps taken in E.O. 12947, to further strengthen and consolidate sanctions to combat the continuing threat posed by international terrorism, and in order to take additional steps to deal with the national emergency declared in E.O. 13224, with respect to the continuing and immediate threat of grave acts of terrorism and threats of terrorism committed by foreign terrorists, which include acts of terrorism that threaten the Middle East peace process.
Section 1 of E.O. 13886 replaces in its entirety section 1 of E.O. 13224, which had been amended by a number of prior Executive orders (E.O. 13224, as amended by all such authorities, is referred to herein as “amended E.O. 13224”), but does not amend the Annex to E.O. 13224, which was previously amended by E.O. 13268 of July 2, 2002, “Termination of Emergency With Respect to the Taliban and Amendment of Executive Order 13224 of September 23, 2001” (67 FR 44751, July 3, 2002) (“amended Annex to E.O. 13224”).
