WASHINGTON -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.
“Through their roles at AQAH, these officials sought to obfuscate Hizballah’s interest in seemingly legitimate transactions at Lebanese financial institutions, exposing these banks to significant AML/CFT risk while allowing Hizballah to funnel money for its own benefit,” said Deputy Secretary Michael Faulkender. “As Hizballah seeks money to rebuild its operations, Treasury remains strongly committed to dismantling the group’s financial infrastructure and limiting its ability to reconstitute itself.”
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.
SANCTIONS EVASION BY AQAH OFFICIALS
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.
Nehme Ahmad Jamil (Jamil) is a senior AQAH official and head of the auditing and business epartments of AQAH. He also manages financial services for Hizballah and its affiliated institutions. For almost 20 years, Jamil has provided financial services to AQAH. In addition, Jamil jointly owns a company, Tashilat SARL, with OFAC-designated Yazbeck and al-Shami. Tashilat SARL provided mortgage loans after the 2006 Israel-Lebanon war, and served as an integral part of the operations for AQAH and designated Hizballah financial institutions Yousser Company and Bayt al-Mal.
Issa Hussein Kassir (Kassir) is a senior AQAH official who oversees the department responsible for supplying equipment to AQAH branches and handling procurement and logistics. In this capacity, Kassir opened bank accounts in the formal financial system to conduct business activities for AQAH. Kassir was documented sending nearly a million dollars to OFAC-designated AQAH shadow bankers Yazbeck, Gharib, and Othman between 2007 and 2019, prior to OFAC’s designation of Jammal Trust Bank SAL (JTB) in 2019. JTB was designated for facilitating the banking activities of U.S.-designated entities openly affiliated with Hizballah, like AQAH and the Martyrs Foundation.
Samer Hasan Fawaz (Fawaz) is the head of the AQAH management division and is responsible for administration and liaising between AQAH and various companies that assist the organization with logistics and procurement. He has served in the role of administrative director for AQAH since at least 2010.
Imad Mohamad Bezz (Bezz) is the head of AQAH’s evaluation and storage department and is responsible for AQAH’s gold deals. Bezz transacted extensively with AQAH officials previously involved in shadow banking activities, including sending over $2.5 million to an account held by three other AQAH officials.
Ali Mohamad Karnib (Karnib) is a senior AQAH employee who serves as the head of AQAH’s purchase department. As of July 2024, Karnib oversaw the purchase of over a thousand ounces of gold for AQAH.
Ali Ahmad Krisht (Krisht) serves as the branch manager of AQAH in Tyre, Lebanon. He previously held at least three bank accounts on behalf of Hizballah and worked in close coordination with OFAC-designated AQAH director Mansour, as well as other AQAH officials. In addition to his ties to AQAH, Krisht was associated with senior Hizballah financial advisor Hassan Moukalled, who was designated in 2023 for providing support to Hizballah and helping Hizballah establish a presence in Lebanon’s financial system.
Mohammed Suleiman Badir (Badir) served as a deputy director of AQAH under designated AQAH official Subayti at the Nabatiyeh branch. He previously held a joint account with Subayti opened as part of a Hizballah plan to circumvent the formal financial system by having members and associates open bank accounts in their personal names.
Jamil, Kassir, Fawaz, Bezz, Karnib, Krisht, and Badir are being designated pursuant to E.O. 13224, as amended, for being owned, controlled, or directed by, or to have acted or purported to act for or on behalf of, directly or indirectly, AQAH.
Tashilat SARL is being designated pursuant to E.O. 13224 for being owned, controlled, or directed by, or to have acted or purported to act for or on behalf of, directly or indirectly, Jamil, Yazbeck, and al-Shami.
SANCTIONS IMPLICATIONS
As a result of today’s action, all property and interests in property of the designated or blocked persons described above that are in the United States or in the possession or control of U.S. persons are blocked and must be reported to OFAC. In addition, any entities that are owned, directly or indirectly, individually or in the aggregate, 50 percent or more by one or more blocked persons are also blocked. Unless authorized by a general or specific license issued by OFAC, or exempt, OFAC’s regulations generally prohibit all transactions by U.S. persons or within (or transiting) the United States that involve any property or interests in property of designated or otherwise blocked persons.
Violations of U.S. sanctions may result in the imposition of civil or criminal penalties on U.S. and foreign persons. OFAC may impose civil penalties for sanctions violations on a strict liability basis. OFAC’s Economic Sanctions Enforcement Guidelines provide more information regarding OFAC’s enforcement of U.S. economic sanctions. In addition, financial institutions and other persons may risk exposure to sanctions for engaging in certain transactions or activities with designated or otherwise blocked persons. The prohibitions include the making of any contribution or provision of funds, goods, or services by, to, or for the benefit of any designated or blocked person, or the receipt of any contribution or provision of funds, goods, or services from any such person.
Furthermore, engaging in certain transactions involving the persons designated today may risk the imposition of secondary sanctions on participating foreign financial institutions. OFAC can prohibit or impose strict conditions on opening or maintaining, in the United States, a correspondent account or a payable-through account of a foreign financial institution that knowingly conducts or facilitates any significant transaction on behalf of a person who is designated pursuant to the relevant authority.