Yesterday, OFAC designated the following persons:
BAZZI, Wael (a.k.a. BAZZI, Wa’el; a.k.a. BAZZI, Wa’il Muhammad), Eglantierlaan 15, Antwerpen 2020, Belgium; DOB 01 Oct 1989 to 31 Oct 1989; alt. DOB 31 Oct 1989; POB Freetown, Sierra Leone; nationality Belgium; Additional Sanctions Information – Subject to Secondary Sanctions Pursuant to the Hizballah Financial Sanctions Regulations; Gender Male; Passport EN312261 (Belgium); National ID No. 89103150321 (individual) [SDGT] (Linked To: BAZZI, Mohammad Ibrahim).
TABAJA, Hassan (a.k.a. TABAJA, Hasan; a.k.a. TABAJA, Hasan Husayn; a.k.a. TABAJA, Hassan Hussain), Lebanon; DOB 08 Oct 1971; POB Chiah, Lebanon; Additional Sanctions Information – Subject to Secondary Sanctions Pursuant to the Hizballah Financial Sanctions Regulations; Gender Male; Passport RL 0913767 (Lebanon); Identification Number 371923 (Lebanon); Residency Number 62270869 (United Arab Emirates) (individual) [SDGT] (Linked To: TABAJA, Adham Husayn).
BSQRD LIMITED, Mansion House Manchester Road, Altrincham Chesire WA14 4RW, United Kingdom; Additional Sanctions Information – Subject to Secondary Sanctions Pursuant to the Hizballah Financial Sanctions Regulations; D-U-N-S Number 22-369-0096; Company Number 11207847 (United Kingdom) [SDGT] (Linked To: BAZZI, Wael).
OFFISCOOP NV, Frankrijklei 156, 5eVerd, Antwerpen 2000, Belgium; Additional Sanctions Information – Subject to Secondary Sanctions Pursuant to the Hizballah Financial Sanctions Regulations; D-U-N-S Number 37-163-1008; Branch Unit Number 2093373727 (Belgium); Enterprise Number 0473365047 (Belgium) [SDGT] (Linked To: BAZZI, Wael).
VOLTRA TRANSCOR ENERGY BVBA (a.k.a. VOLTRA TRANSCOR ENERGY; f.k.a. “SOFTLINE”), Frankrijklei 156 (5deV), Antwerpen 2000, Belgium; Additional Sanctions Information – Subject to Secondary Sanctions Pursuant to the Hizballah Financial Sanctions Regulations; D-U-N-S Number 37-339-4675; V.A.T. Number BE0443680473 (Belgium); Branch Unit Number 2052342727 (Belgium); Enterprise Number 0443680473 (Belgium) [SDGT] (Linked To: BAZZI, Wael).
under the Hizballah Financial Sanctions Regulations, part of its counter terrorism sanctions program which come with secondary sanctions attached.
In addition, OFAC updated an existing designation:
GLOBAL TRADING GROUP NV (a.k.a. GLOBAL TRADING GROUP), Frankrijklei 39, 2nd Floor, Antwerpen 2000, Belgium; 22 Liverpool Street, Freetown, Sierra Leone; Standard Chartered Bank Building, 2nd floor, Kairaba Ave, Banjul, The Gambia; Rue de Canal, G83 Zone 4G, 01BP1280, Abidjan, Cote d Ivoire; Quartier les Cocotiers, Avenue Pape Jean Paul II, Lot 4274, Cotonou, Benin; Website http://www.globaltradinggroup.com; Additional Sanctions Information – Subject to Secondary Sanctions Pursuant to the Hizballah Financial Sanctions Regulations; D-U-N-S Number 37-117-1419 [SDGT] (Linked To: BAZZI, Mohammad Ibrahim). -to- ENERGY ENGINEERS PROCUREMENT AND CONSTRUCTION (a.k.a. GLOBAL TRADING GROUP; a.k.a. GLOBAL TRADING GROUP NV; a.k.a. “EEPC”), Frankrijklei 39, 2nd Floor, Antwerpen 2000, Belgium; 22 Liverpool Street, Freetown, Sierra Leone; Standard Chartered Bank Building, 2nd floor, Kairaba Ave, Banjul, The Gambia; Rue de Canal, G83 Zone 4G, 01BP1280, Abidjan, Cote d Ivoire; Quartier les Cocotiers, Avenue Pape Jean Paul II, Lot 4274, Cotonou, Benin; Frankrijklei 156 (5th floor), Antwerpen 2000, Belgium; Website http://www.globaltradinggroup.com; Additional Sanctions Information – Subject to Secondary Sanctions Pursuant to the Hizballah Financial Sanctions Regulations; D-U-N-S Number 37-117-1419 [SDGT] (Linked To: BAZZI, Mohammad Ibrahim).
And Treasury issued the following press release:
Treasury Targets Sanctions Evasion Conduits for Major Hizballah Financiers
Treasury Targets Sanctions Evasion Conduits for Major Hizballah Financiers
Washington – Today, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) further targeted the global business operations of Hizballah by designating two individuals and three entities acting as conduits for sanctions evasion schemes. Specifically, OFAC designated Belgium-based Wael Bazzi for acting for or on behalf of his father and Hizballah financier, Mohammad Bazzi. OFAC designated Belgium-based Voltra Transcor Energy BVBA, Belgium-based OFFISCOOP NV, and United Kingdom-based BSQRD Limited for being owned or controlled by Wael Bazzi. OFAC is also adding Energy Engineers Procurement and Construction as an alias for Global Trading Group NV (GTG), one of Mohammad Bazzi’s companies, which was designated in May 2018. Additionally, OFAC designated Lebanon-based Hassan Tabaja for acting for or on behalf of his brother and Hizballah member and financier, Adham Tabaja. These individuals and entities were designated under Executive Order (E.O.) 13224, which targets terrorists and those providing support to terrorists or acts of terrorism.
“Treasury is relentlessly pursuing Hizballah’s financial facilitators by dismantling two of Hizballah’s most important financial networks. As Hizballah continues to attempt to obscure its activities by using seemingly legitimate businesses, we will continue to take action against the front persons who hide the movement of money, including the relatives of designated terrorists,” said Sigal Mandelker, Treasury Under Secretary for Terrorism and Financial Intelligence. “By targeting Hassan Tabaja and Wael Bazzi and their European-based companies, this Administration is continuing to disrupt all avenues of financial support relied upon by Hizballah.”
DESIGNATIONS BUILD ON REWARDS FOR JUSTICE PROGRAM
Today’s designation of Hassan Tabaja and Wael Bazzi and his companies builds on the State Department’s April 22, 2019 announcement of a Rewards for Justice (RFJ) reward offer for information leading to the disruption of Hizballah’s financial mechanisms. The program provides rewards for information that helps bring terrorists to justice, prevents international acts of terrorism against U.S. persons or property, leads to the identification or location of a key terrorist leader, or disrupts terrorist financing. OFAC is designating individuals and entities connected to two of the financiers highlighted in that announcement, Mohammad Bazzi and Adham Tabaja. For more information about the reward offer or to submit information on Hizballah’s financial networks, visit the Rewards for Justice website at www.rewardsforjustice.net or contact the Rewards for Justice office via the confidential e-mail at LH@rewardsforjustice.net.
Today’s action also builds on the unprecedented number of designations taken in 2018 exposing Hizballah’s terrorist support networks and pervasive use of seemingly legitimate businesses to launder money and foment regional conflict. Hizballah and its proxies continue to use deceptive practices to circumvent sanctions, such as the use of family members and others to gain access to the formal financial system both in Lebanon and beyond. As a standard practice, the regulated public should undertake know-your-customer due diligence to ensure awareness of the ultimate beneficiaries of transactions. In cases with known links to designated terrorists, enhanced due diligence should be applied to ensure that the underlying activity is not in violation of U.S. sanctions. The Treasury Department is determined to protect the integrity of the U.S., Lebanese, and international financial system to ensure that Hizballah cannot exploit them to further its political, financial, or operational agenda.
As a result of today’s action, all property and interests in property of these persons, and of any entities that are owned, directly or indirectly, 50 percent or more by the designated persons, that are in the United States or in the possession or control of U.S. persons are blocked and must be reported to OFAC. OFAC’s regulations generally prohibit all dealings by U.S. persons or within (or transiting) the United States that involve any property or interests in property of blocked or designated persons.
Additionally, the two individuals and three entities designated today are subject to secondary sanctions pursuant to the Hizballah Financial Sanctions Regulations, which implements the Hizballah International Financing Prevention Act of 2015. Pursuant to this authority, OFAC can prohibit or impose strict conditions on the opening or maintaining in the United States of a correspondent account or a payable-through account by a foreign financial institution that knowingly facilitates a significant transaction for Hizballah, or a person acting on behalf of or at the direction of, or owned or controlled by, Hizballah.
Hizballah was designated by the Department of State as a Foreign Terrorist Organization in October 1997 and as a Specially Designated Global Terrorist (SDGT) pursuant to E.O. 13224 in October 2001. It was listed in January 1995 in the Annex to E.O. 12947, which targets terrorists who threaten to disrupt the Middle East peace process, and also designated in August 2012 pursuant to E.O. 13582, which targets the Government of Syria and its supporters.
BACKGROUND ON ADHAM TABAJA AND MOHAMMAD BAZZI
OFAC designated Adham Tabaja as an SDGT in June 2015 for providing support and services to Hizballah. Adham Tabaja is a Hizballah member and majority owner of the designated Lebanon-based real estate development and construction firm Al-Inmaa Group for Tourism Works and its subsidiaries. His company has been used by Hizballah as an investment mechanism. He maintains direct ties to senior Hizballah organizational elements, including the terrorist group’s operational component, the Islamic Jihad, the unit responsible for carrying out the group’s overseas terrorist activities. Specifically, Islamic Jihad member Husayn Ali Faour, whom OFAC designated concurrently with Adham Tabaja in June 2015, has worked with Adham Tabaja to secure and manage construction, oil, and other projects in Iraq. Adham Tabaja’s global network of seemingly legitimate businesses combined with his ties to Hizballah’s terrorist unit make it critically important that his access to the international financial system is severed to ensure that he cannot fund this terrorist group.
Adham Tabaja maintains ties to other major Hizballah financiers, including Mohammad Bazzi, whom OFAC designated as an SDGT in May 2018 for assisting in, sponsoring, or providing financial, material, or technological support for, or financial or other services to or in support of, Hizballah. Mohammad Bazzi, who operates or transacts in or through Belgium, Lebanon, Iraq, and several countries in West Africa, provided Hizballah financial assistance for many years and has provided millions of dollars to Hizballah generated from his business activities. In addition, Mohammad Bazzi was a close associate of Yahya Jammeh who was identified on December 20, 2017, in the annex to E.O. 13818, which implemented the Global Magnitsky Human Rights Accountability Act. Since his designation in May 2018, Mohammad Bazzi has continued to work with other Treasury-designated, senior Hizballah members.
Wael Bazzi was designated for acting for or on behalf of Mohammad Bazzi.
Since his designation in May 2018, Mohammad Bazzi has turned to his son, Wael Bazzi, to continue doing business in the Gambia. Mohammad Bazzi has been able to conduct business through Wael Bazzi, upon whom he has continued to rely on to register new businesses and bid on Gambian government contracts. Wael Bazzi formed a petroleum company to maintain his father’s access to the oil industry. Additionally, Mohammad Bazzi coordinated with Wael Bazzi and a Belgium-based GTG employee to change GTG’s name after GTG’s designation. Wael Bazzi was the purported owner of this new company, likely to obscure Mohammad Bazzi’s involvement and circumvent Mohammad Bazzi‘s designation.
Wael Bazzi has helped Mohammad Bazzi and a Lebanon-based associate facilitate payments for a business contract. Additionally, Wael Bazzi likely established an account for Voltra Transcor Energy, in connection with Mohammad Bazzi’s attempted use of an intermediary company to move money to GTG and circumvent OFAC sanctions. In 2017, Mohammad Bazzi planned to submit his son, Wael Bazzi, to fill the Lebanese Consular position in the Gambia because he could exert his influence over Wael. As of at least early 2018, Wael Bazzi has been witting of Mohammad Bazzi’s involvement in illicit activity.
On August 9, 2018, GTG changed its name to Energy Engineers Procurement and Construction.
DESIGNATED WAEL BAZZI-OWNED OR -CONTROLLED COMPANIES
Voltra Transcor Energy BVBA
Voltra Transcor Energy BVBA was designated for being owned or controlled by Wael Bazzi.
Wael Bazzi is the Chief Executive of Belgium-based Voltra Transcor Energy BVBA, which is involved in the petroleum products industry. Wael Bazzi established an account for Voltra Transcor Energy, which Mohammad Bazzi attempted to use as an intermediary company to move money to GTG and circumvent OFAC sanctions.
OFFISCOOP NV was designated for being owned or controlled by Wael Bazzi.
Wael Bazzi is the Chief Executive, Managing Director, and Director of Belgium-based OFFISCOOP NV, which is involved in the management consulting services industry.
BSQRD Limited was designated for being owned or controlled by Wael Bazzi.
Wael Bazzi is the Chief Executive, Director, and 50% owner of United Kingdom-based BSQRD Limited, which is involved in the computer-related services industry.
Hassan Tabaja was designated for acting for or on behalf of Adham Tabaja.
Hassan Tabaja managed multiple properties in the United Arab Emirates (UAE) belonging to his brother, Adham Tabaja; however, in the summer of 2018 Emirati authorities took swift action against Hassan Tabaja and the assets he controlled as a result of his nefarious activities. Hassan Tabaja is the legal representative for Adham Tabaja, has Power of Attorney (PoA) for him, and is named the executor of his property. Accordingly, Hassan Tabaja was granted the power to make legal, real estate, and financial decisions; sign for business matters; buy and sell vehicles; take out loans; take out insurance policies; and cancel the PoA and any agreements in conjunction with and on behalf of Adham Tabaja.
Hassan Tabaja, likely on behalf of Adham Tabaja, has also pursued business transactions with Mohamad Noureddine, a Lebanese money launderer, whom OFAC designated as a SDGT pursuant to E.O. 13224 in January 2016, for providing financial services to or in support of, Hizballah.
What Mr. Watchlist wants to know is – did these designations directly derive from the reward offered just two days earlier under the Rewards for Justice program? If so, we are all dutifully impressed….