Important News

U.S. Treasury Sanctions Jood SARL and Regional Associates for Facilitating Hizballah Funding

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Key takeaways

  • OFAC sanctioned Lebanese gold exchange Jood SARL for converting Hizballah’s gold reserves into usable funds and operating under the supervision of Al-Qard Al-Hassan (AQAH).
  • Individuals designated include senior AQAH official Mohamed Nayef Maged; other persons and firms sanctioned include Andrey Borisov, Platinum Group International Dis Ticaret Limited Sirketi, Sea Surf Shipping Limited, and Brilliance Maritime Ventures S.A.
  • OFAC identified the vessels BRILLIANCE and LARA as blocked property in the interest of their respective owners.
  • Designations were made under Executive Order 13224, the U.S. counterterrorism sanctions authority, and reflect Hizballah’s use of AQAH and regional procurement/shipping schemes to raise revenue and evade sanctions.
  • All U.S. property and interests of the designated and blocked parties are frozen; U.S. persons are generally prohibited from transacting with them unless authorized by OFAC.
  • OFAC warned that foreign financial institutions could face secondary sanctions or restrictions (e.g., blocking correspondent accounts) if they knowingly facilitate significant transactions for designated persons.
  • OFAC provides a petition process for removal from the SDN List and refers interested parties to guidance on filing for delisting.

Follow Up Questions

What is the Office of Foreign Assets Control (OFAC) and what authority does it have to impose sanctions?Expand

OFAC (Office of Foreign Assets Control) is the U.S. Treasury office that administers and enforces U.S. economic sanctions. It operates under statutes and presidential authorities (notably the International Emergency Economic Powers Act, IEEPA, and the Trading with the Enemy Act) and issues regulations, blocks property, and adds persons/entities to sanctions lists to advance U.S. foreign policy and national security goals.

What does Executive Order 13224 authorize and why is it being used here?Expand

Executive Order 13224 (issued after 9/11) authorizes the U.S. government to block property and prohibit transactions with persons who commit, threaten to commit, or support terrorism. OFAC uses E.O. 13224 to designate terrorists and their facilitators (freezing U.S.-based assets and forbidding U.S. persons from dealing with them).

What is the SDN List and what does it mean for an entity to be added to it?Expand

The SDN (Specially Designated Nationals) List is OFAC’s public list of individuals, groups, and entities (e.g., terrorists, narcotics traffickers, front companies) whose U.S.-based assets are blocked; U.S. persons are generally prohibited from transacting with SDNs.

What does the term "blocked property" mean in practice for companies and banks?Expand

"Blocked property" means any property or interests in property in which a designated person has an interest that are within U.S. jurisdiction; U.S. persons must freeze (block) such assets and generally may not transfer, pay, or deal in them without an OFAC license.

What is Al-Qard Al-Hassan (AQAH) and how does it operate in Lebanon’s financial system?Expand

Al‑Qard al‑Hassan (AQAH) is a network of Lebanon-based charitable/credit societies associated with Hizballah that provide savings, loans and cash services (often interest‑free) to communities and Hizballah members; it functions informally as a parallel banking and social-support mechanism and can be used to move and convert value (including gold) outside formal banking channels.

How will these sanctions affect ordinary Lebanese people who rely on cash and informal financial services?Expand

Sanctions against AQAH-linked firms that convert gold or run informal finance networks can reduce avenues for converting assets into cash, prompt correspondent banks and foreign institutions to restrict services to Lebanese counterparts (de‑risking), and aggravate existing cash shortages — meaning ordinary Lebanese who rely on cash, money exchanges, or community credit may face reduced access to services, longer delays, and higher costs.

What are "secondary sanctions" and how could they affect foreign banks that do business with designated parties?Expand

Secondary sanctions are measures the U.S. can apply to foreign persons or institutions that knowingly facilitate significant transactions for designated parties (e.g., blocking access to U.S. correspondent banking, denying U.S. market access). They create incentives for banks and companies worldwide to avoid dealing with designated entities to protect U.S. access and services.

How can a designated person or entity seek removal from OFAC’s SDN List?Expand

A designated person or entity can petition OFAC for removal (a "delisting" petition) under OFAC’s procedures (see 31 C.F.R. §501.807). OFAC’s website explains how to file a petition and the documentation and review process for seeking removal from the SDN List.

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