Today, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated Lebanon-based Green Without Borders and its leader. Green Without Borders is a Lebanon-based organization that has provided support to and cover for Hizballah’s operations in southern Lebanon along the “Blue Line” between Lebanon and Israel over the last decade while publicly operating under the guise of environmental activism. OFAC is designating Green Without Borders and its leader, Zuhair Subhi Nahla, pursuant to Executive Order (E.O.) 13224, as amended, which targets terrorists, terrorist organizations, leaders and officials of terrorist groups, and those providing support to terrorists or acts of terrorism. Green Without Borders (GWB) was established in 2013 with the ostensible purpose of protecting Lebanon’s natural environment, including reforestation activities. In reality, it has served as a cover for Hizballah’s activities in southern Lebanon along the Blue Line, where GWB has outposts manned by Hizballah operatives in more than a dozen locations. These outposts, which are manned by Hizballah operatives, serve as cover for Hizballah’s underground warehouses and munitions storage tunnels. These installations have impeded United Nations Interim Force in Lebanon peacekeepers from fulfilling their UN Security Council (UNSC) mandate to monitor the implementation of UNSC Resolution 1701 and have prevented oversight of these outposts. Under the cover of GWB outposts, Hizballah members conduct weapons training at firing ranges, patrol the surrounding area, and maintain containerized housing units 25 meters from the Blue Line. Alleged encroachment on private property by GWB and Hizballah and propagandizing by GWB have also caused well-documented clashes with locals.
Since 2013, GWB has used its resources to support Hizballah activity at GWB outposts and has also publicly partnered with the Hizballah’s construction arm, Jihad al-Bina, which was designated by OFAC in 2007. Collaboration between GWB and Hizballah is widely reported in the media, including by official Hizballah media outlets.
GWB is being designated pursuant to Section 1(a)(iii)(C) of E.O. 13224, as amended, for materially assisting, sponsoring, or providing financial, material, or technological support for, or goods or services to or in support of, Hizballah.
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”).
