Today, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated two Lebanese brothers — Raymond Zina Rahme and Teddy Zina Rahme — who used their wealth, power, and influence to engage in corrupt practices that contribute to the breakdown of the rule of law in Lebanon, thereby undermining Lebanon’s democratic processes to the detriment of the Lebanese people. At a time when the Lebanese people face significant economic distress, a dire energy crisis, and unprecedented political dysfunction, the Rahme brothers have used their business empire and political connections to enrich themselves at the expense of their fellow citizens. Raymond Zina Rahme and his brother, Teddy Zina Rahme, have used companies under their control — located both inside and outside of Lebanon — to win multiple government contracts through a highly opaque public tendering process. In 2017, the Rahme brothers secured a subcontract to import fuel for use by Lebanon’s state-owned national electricity utility, Électricité du Liban (EdL), and to import fuel on behalf of the Lebanese Ministry of Energy and Water in a bidding process widely reported to be corrupt. While contracted, the Rahme brothers imported tainted fuel, causing significant harm to Lebanese power plants. The Rahme brothers, through their UAE-based company ZR Energy DMCC, passed off their dangerously compromised fuel product by blending it with other fuels. While the Rahme brothers enriched themselves with this scheme, the Lebanese people suffered, and the country’s infrastructure further deteriorated. Power stations across Lebanon increasingly malfunctioned and daily electricity cuts increased.
Raymond Zina Rahme and Teddy Zina Rahme are being designated pursuant to E.O. 13441 for having taken, or for posing a significant risk of taking, actions, including acts of violence, that have the purpose or effect of undermining Lebanon’s democratic processes or institutions, contributing to the breakdown of the rule of law in Lebanon. ZR Energy DMCC is being designated pursuant to E.O. 13441 for being owned or controlled by, directly or indirectly, Raymond Zina Rahme and Teddy Zina Rahme.
The Rahme brothers own and manage Lebanon-based ZR Group Holding SAL, a company operating in the energy, telecommunications, and aviation industries. The Rahme brothers used ZR Group Holding SAL to provide the funding necessary to establish ZR Energy DMCC, ZR Group Holding SAL has used its influence among Lebanese financial institutions to open letters of credit for ZR Energy DMCC, and the two companies share employees. Lebanon-based ZR Logistics SAL is also owned by the Rahme brothers through ZR Group Holding SAL.
ZR Group Holding SAL and ZR Logistics SAL are being designated pursuant to E.O. 13441 for being owned or controlled by, directly or indirectly, Raymond Rahme and Teddy Rahme.
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.
