The United States designated Hizballah as a Foreign Terrorist Organization on October 8, 1997 and as a Specially Designated Global Terrorist on October 31, 2001, and the Gulf Cooperation Council designated Hizballah as a terrorist organization on March 2, 2016. Today, Ali Reda Hassan al-Banai (Ali al-Banai), Ali Reda al-Qassabi Lari (Ali Lari), and Abd al-Muayyid al-Banai (Abd al-Muayyid) are being designated as Specially Designated Global Terrorists (SDGTs) pursuant to Executive Order (E.O.) 13224, as amended, for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, Hizballah. Ali al-Banai and Lari are longstanding supporters of Hizballah and have secretly sent tens of millions of dollars to the terrorist organization through the formal financial system and cash couriers. They both regularly met with Hizballah officials during their travels to Lebanon and Iran. Ali al-Banai initially began contributing funds to Hizballah via another Kuwait-based Hizballah donor and a Kuwait-based branch of the U.S.-designated Martyrs Foundation, which was designated in 2007 for providing financial support to the families of killed or imprisoned terrorists, including suicide bombers in the Palestinian territories. Ali al-Banai and his brother, Abd al-Muayyid, who is also being designated today, held joint accounts in several banks, transferred funds to Hizballah as recently as late 2020, and maintained ties to senior Hizballah associates. In 2017, Ali al-Banai planned to transfer millions of dollars to a senior Hizballah official from a bank account from which Hizballah representatives could also withdraw and transfer funds. Lari has been providing financial support to Hizballah since 2000 when he would deliver cash to Hizballah during his trips to Lebanon. During a trip to Iran, Lari met with a high-ranking Hizballah official to transfer funds to the group. As of 2018, Lari was involved in financial facilitation activities supporting Hizballah and worked with al-Banai to move money from Qatar to Hizballah-run organizations.
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”).
