Today, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned former Lebanese government ministers Yusuf Finyanus and Ali Hassan Khalil, who provided material support to Hizballah and engaged in corruption. Ali Hassan Khalil previously served as the Minister of Finance (2014-2020) and Minister of Public Health (2011-2014). As Minister of Finance, Khalil was one of the officials Hizballah leveraged a relationship with for financial gain. In late 2017, shortly before the Lebanese parliamentary elections that would take place in May 2018, Hizballah leaders, fearing a weakening of their political alliance with the Amal Movement, reached an agreement with Khalil where he was prepared to receive Hizballah support for his political success. Khalil worked to move money in a manner that would avoid U.S. sanctions enforcement from government ministries to Hizballah-associated institutions. Additionally, Khalil used his position as Minister of Finance to attempt to have U.S. financial restrictions on Hizballah eased so that the group would have less difficulty moving money. Khalil also used the power of his office to exempt a Hizballah affiliate from paying most taxes on electronics imported to Lebanon, and a portion of what was paid was collected to support Hizballah. As of late 2019, Khalil as Finance Minister refused to sign checks payable to government suppliers in an effort to solicit kickbacks. He demanded that a percentage of the contracts be paid to him directly.
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”).
