Assi has materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, Adham Tabaja, a person whose property and interests in property are blocked pursuant to E.O. 13224, as amended.
In the years following his designation, Tabaja maintained close financial connections to Assi, receiving millions from accounts tied to Assi. As of 2019, Assi was one of Tabaja’s few remaining sources of financial support. Assi is also a business partner of Tabaja and conducts real estate purchases on his behalf. In turn, Tabaja has used his ties with Hizballah to solve Assi’s business and legal problems.
Assi uses his companies to facilitate payments to Tabaja. Assi and his companies also engage in tax evasion and money laundering schemes in the DRC that generate illicit profits of tens of millions of dollars per year, a portion of which are transferred to Tabaja in Lebanon. Revenue generated by Assi’s schemes is delivered to Lebanon via bulk cash transfers or laundered through Nazem Ahmad’s diamond businesses. Over the past decade, Assi has used schemes like these to funnel tens of millions of dollars to Tabaja. Assi was also involved in a tax evasion scheme with several other U.S. designated Hizballah financiers and associates, including Tabaja, Nazem Ahmad, Mohammad Bazzi, and Kassem Tajideen.
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”).
