Street 10, Matn District, Rabieh, Mount Lebanon, Lebanon;
United Kingdom
Reg. ID
282003, Passport
Official reason
Diverted funds were frequently transferred to a number of property management companies in France, Germany, Luxembourg, and Belgium that were registered in the names of either Salameh’s son, Nady Salameh (Nady), or Salameh’s former partner, Anna Kosakova (Anna). Nady was the publicly registered officer of companies registered in Luxembourg that used subsidiaries in Germany and Belgium to purchase high-end commercial real estate worth tens of millions of dollars. In France, Anna owned companies that received funds from Forry Associates and used those funds to purchase luxury properties, including apartments for Anna and Salameh in one of Paris’ most sought-after neighborhoods, and an office building on the Champs-Elysées where the BdL rented space for its “continuity of operations” center.
Salameh also used shell companies in Panama and a trust in Luxembourg to hide his identity as he purchased shares in a company where his son, Nady, had worked as an investment advisor, only to later sell those shares to a Lebanese bank regulated by the BdL. This sale represents both a conflict of interest as well as a likely violation of a Lebanese law prohibiting employees of the BdL from profiting from other private businesses, enacted to ensure that they devote their attention entirely to safeguarding Lebanon’s economic prosperity.
Salameh is being designated pursuant to E.O. 13441 for having taken, or posing a threat of taking, actions that have the purpose or effect of contributing to the breakdown of the rule of law in Lebanon. Raja, Nady, Anna, and Marianne are being designated pursuant to E.O. 13441 for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, Salameh.
Lebanon Sanctions Regulations, 31 C.F.R. part 549; Executive Order 13441 of August 1, 2007 Blocking Property of Persons Undermining the Sovereignty of Lebanon or Its Democratic Processes and Institutions
Regime
OFAC country specific
Target State
Lebanon
Measures
Blocking Property
Official Information
On August 1, 2007, the President, invoking the authority of, inter alia, the International Emergency Economic Powers Act (50 U.S.C. 1701–1706) (“IEEPA”), issued Executive Order 13441 (72 FR 43499, Aug. 3, 2007) (“E.O. 13441”). In E.O. 13441, the President determined that the actions of certain persons to undermine Lebanon's legitimate and democratically elected government or democratic institutions, to contribute to the deliberate breakdown of the rule of law in Lebanon, including through politically motivated violence and intimidation, to reassert Syrian control or contribute to Syrian interference in Lebanon, or to infringe upon or undermine Lebanese sovereignty contribute to political and economic instability in Lebanon and the region and constitute an unusual and extraordinary threat to the national security and foreign policy of the United States. To deal with that threat, the President declared a national emergency. E.O. 13441 then sets forth the actions ordered by the President.
