Today, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) is sanctioning seven senior officials and one entity associated with the Hizballah-controlled financial institution Al-Qard Al-Hassan (AQAH), which was designated by OFAC in 2007. These officials have served in senior management roles for AQAH and have facilitated the evasion of U.S. sanctions, enabling Hizballah’s access to the formal financial system. Today’s action underscores Treasury’s commitment to disrupting Hizballah’s sanctions evasion schemes and supporting efforts by the new Lebanese government to limit the terrorist group’s influence, particularly as entities like AQAH continue to undermine the already fragile Lebanese economy. Today’s action maintains pressure on Hizballah, building on several actions targeting the group’s illicit finance networks involved in financial facilitation, oil sales, and other commercial enterprises. Treasury previously targeted AQAH shadow bankers in 2021, identifying AQAH’s financial director, Ahmad Mohamad Yazbeck (Yazbeck), along with officials Abbas Hassan Gharib (Gharib), Wahid Mahmud Subayti (Subayti), Mostafa Habib Harb (Harb), Ezzat Youssef Akar (Akar), and Hasan Chehada Othman (Othman) for acting on behalf of AQAH to evade sanctions. Treasury sanctioned AQAH Executive Director Adel Mansour (Mansour) in 2022. Husayn al-Shami (al-Shami), who ran AQAH at the time of its designation in 2007, was designated in 2006 for supporting Hizballah. Today’s action is being taken pursuant to Executive Order (E.O.) 13224, as amended. The Department of State designated Hizballah as a Specially Designated Global Terrorist (SDGT) pursuant to E.O. 13224 on October 31, 2001. The AQAH officials targeted today serve in critical roles for the organization’s activities in support of Hizballah, and some have been associated with AQAH for over two decades. In addition to their employment with AQAH, several have previously held joint bank accounts at Lebanese financial institutions in coordination with other AQAH affiliates and conducted millions of dollars in transactions that ultimately benefitted, but obscured, Hizballah’s interest. Many of the transactions in these accounts reflected the same pattern as the previously OFAC-designated “shadow bankers” where AQAH officials would conduct mirrored financial activity in AQAH accounts against proxy bank accounts within the formal Lebanese financial system to disguise the movement of money associated with known Hizballah members.
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”).
