August 29, 2019: OFAC sanctions financial firms and persons facilitating Hizballah’s finances

On Thursday, OFAC designated the following persons:

AL-AYY, Muhammad Kamal (a.k.a. ALAY, Muhammad Kamal Salamah), Gaza, Palestinian; DOB 22 Dec 1970; Gender Male; National ID No. 912396140 (Palestinian) (individual) [SDGT] (Linked To: HAMAS). 

 

AWAD, Kamal Abdelrahman Aref (a.k.a. AWAD, Kamal), Gaza, Palestinian; DOB 07 Aug 1978; POB Nablus, West Bank; Gender Male; National ID No. 905037545 (Palestinian) (individual) [SDGT] (Linked To: HAMAS). 

 

NASSER, Fawaz Mahmud Ali (a.k.a. NASIR, Fawwaz), Gaza, Palestinian; DOB 13 Jan 1979; POB Ramallah, West Bank; Gender Male; National ID No. 946045622 (Palestinian) (individual) [SDGT] (Linked To: HAMAS). 

 

SARUR, Muhammad (a.k.a. SURUR, Muhammad Ibrahim), Baalbek-Hermel Province, Lebanon; DOB 05 Feb 1967; Gender Male (individual) [SDGT] (Linked To: HAMAS).

and entities:

JAMMAL TRUST BANK S.A.L. (a.k.a. JAMMAL TRUST BANK; a.k.a. “JTB”), JTB Tower, Elias Hraoui Avenue, Beirut, Lebanon; Jammal Trust Bank SAL Building, Rashid Karame Ave, Beirut, Lebanon; PO Box 11-5640 & 13-5750, Bank’s Bldg, Rashid Karameh Ave, Beirut, Lebanon; SCI La Balance, Boulevard Giscard D’estaing, Abidjan, Cote d Ivoire; 15A Burma Road, Apapa, Lagos State, Nigeria; 3rd Floor, Berkeley Court, 6/7 Pollen St, London W1S 1ND, United Kingdom; Al-Buss, Lebanon; Al Furzol, Lebanon; Baalbeck, Lebanon; Beirut, Lebanon; Bint Jbeil, Lebanon; Bourj El Barajneh, Lebanon; Dora, Lebanon; Ghazieh, Lebanon; Jbeil, Lebanon; Jwaya, Lebanon; Kana, Lebanon; Labwe, Lebanon; Marjeyoun, Lebanon; Nabatieh, Lebanon; Saida, Lebanon; Tibnin, Lebanon; Tripoli, Lebanon; Tyre, Lebanon; Verdun, Lebanon; Abidjan, Cote d Ivoire; Apapa, Nigeria; London, United Kingdom; SWIFT/BIC JTBKLBBE; Additional Sanctions Information – Subject to Secondary Sanctions Pursuant to the Hizballah Financial Sanctions Regulations; All Branches Worldwide [SDGT] (Linked To: HIZBALLAH). 

 

TRUST INSURANCE S.A.L. (a.k.a. TRUST INSURANCE), JTB Tower, Tahweeta High Way, Elias Hraoui Avenue, Beirut, Lebanon; PO Box 15750, Jammal Trust Bank Building, Rachid Karameh Street, Verdun, Lebanon; Verdun, Lebanon; Additional Sanctions Information – Subject to Secondary Sanctions Pursuant to the Hizballah Financial Sanctions Regulations [SDGT] (Linked To: JAMMAL TRUST BANK S.A.L.). 

 

TRUST INSURANCE SERVICES S.A.L., JTB Tower, Tahweeta High Way, Elias Hraoui Avenue, Beirut, Lebanon; Lebanon; Additional Sanctions Information – Subject to Secondary Sanctions Pursuant to the Hizballah Financial Sanctions Regulations [SDGT] (Linked To: JAMMAL TRUST BANK S.A.L.). 

 

TRUST LIFE INSURANCE COMPANY S.A.L. (a.k.a. TRUST LIFE; a.k.a. TRUST LIFE INSURANCE CO SAL), JTB Tower, Tahweeta High Way, Elias Hraoui Avenue, Beirut, Lebanon; Jamal Trust Vabk Building, Beirut, Lebanon; Beirut, Lebanon; Additional Sanctions Information – Subject to Secondary Sanctions Pursuant to the Hizballah Financial Sanctions Regulations [SDGT] (Linked To: JAMMAL TRUST BANK S.A.L.).

under its counter terrorism program.

And both Treasury and State issued multiple press releases – here is Treasury’s for the individuals:

PRESS RELEASES

Treasury Targets Facilitators Moving Millions to HAMAS in Gaza

Washington – Today, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC), in partnership with the Sultanate of Oman, designated financial facilitators responsible for moving tens of millions of dollars between Iran’s Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF) and HAMAS’s operational arm, the Izz-Al-Din Al-Qassam Brigades in Gaza.  OFAC designated Muhammad Sarur, Kamal Abdelrahman Aref Awad, Fawaz Mahmud Ali Nasser, and Muhammad Kamal al-Ayy for providing financial, material, technological support, financial or other services to, or in support of, HAMAS.  These individuals were designated under Executive Order (E.O.) 13224, which targets terrorists and those providing support to terrorists or acts of terrorism.

“These facilitators funneled tens of millions of dollars from Iran’s Qods Force through Hizballah in Lebanon to HAMAS for terrorist attacks originating from the Gaza Strip.  HAMAS’s continued violent campaign against innocent civilians and the state of Israel is to the great detriment of the people in Gaza,” said Sigal Mandelker, Treasury’s Under Secretary for Terrorism and Financial Intelligence.  “This Administration will not falter to hold HAMAS and its Iranian leaders accountable for their violence.  Treasury will continue to disrupt terrorist networks by targeting those who generate funds to carry out the Iranian regime’s violent agenda.”

The Lebanon and Gaza-based financial facilitators targeted today are critical intermediaries between the Iranian regime, and the Izz-Al-Din Al-Qassam Brigades and end users in the West Bank.  At the center of this scheme is a Lebanon-based financial operative, Muhammad Sarur, who has been identified as being in charge of all financial transfers between the IRGC-QF and the Izz-Al-Din Al-Qassam Brigades, and has an extensive history working at Hizballah’s sanctioned bank, Bayt al-Mal.  Bayt al-Mal was designated by OFAC in 2006 for being owned or controlled by, and acting for or on behalf of Hizballah.  Also sanctioned today are three Gaza-based individuals who have been integral to providing funding to HAMAS’s prisoner and martyrs infrastructure in the West Bank and Gaza.

HAMAS was designated by the Department of State as a Foreign Terrorist Organization (FTO) in October 1997 and as a Specially Designated Global Terrorist (SDGT) pursuant to E.O. 13224 in October 2001.  It was also listed as a Specially Designated Terrorist (SDT) in January 1995 in the Annex to E.O. 12947, which targets terrorists who threaten to disrupt the Middle East peace process.

MUHAMMAD SARUR

Muhammad Sarur (Sarur) provides financial, material, technological support, financial or other services to or in support of, HAMAS.

Sarur, a Beirut, Lebanon-based HAMAS and Hizballah-linked financial operative, is in charge of transferring tens of millions of dollars per year from the IRGC-QF to the Izz-Al-Din Al-Qassam Brigades.  As of 2014, Sarur was identified as in charge of all money transfers from the IRGC-QF to Izz-Al-Din Al-Qassam Brigades.  Overall, in the past four years, the IRGC-QF transferred over U.S. $200 million dollars to the Izz-Al-Din Al-Qassam Brigades.  The IRGC-QF, a branch of the IRGC, has provided material support to numerous terrorist groups.  The IRGC-QF is a designated FTO and SDGT, and the Izz-Al-Din Al-Qassam Brigades is a designated FTO, SDGT, and SDT.

Sarur served as a middle-man between the IRGC-QF and HAMAS and worked with Hizballah operatives to ensure funds were provided to the Izz-Al-Din Al-Qassam Brigades.  In 2011 and extending through 2016, Sarur worked for Hizballah’s Bayt al-Mal.  To transfer funds to HAMAS in Gaza, Sarur coordinated transfers through an individual who served as a Gaza-based HAMAS financial facilitator and money smuggling operations officer.

KAMAL ABDELRAHMAN AREF AWAD

Kamal Abdelrahman Aref Awad (Awad) provides financial, material, technological support, financial or other services to or in support of, HAMAS.

In early 2018, Awad, a Gaza-based HAMAS financial associate, coordinated with the same Gaza-based HAMAS financial facilitator, leveraged by Sarur, to provide hundreds of thousands of dollars in deposits for HAMAS.

As of 2017, the Izz-Al-Din Al-Qassam Brigades worked through Awad to distribute funds to the families of “martyrs” in the West Bank.  Also in 2017, Awad coordinated the mismanagement of certain HAMAS prisoner entitlement funds.  As of early 2016, HAMAS senior official Salih al-Aruri relied on Awad for detailed information regarding HAMAS prisoners and payments to HAMAS prisoners.  Salih al-Aruri was designated by OFAC as an SDGT in September 2015 for acting for or on behalf of, and providing financial support to, HAMAS.

FAWAZ MAHMUD ALI NASSER & MUHAMMAD AL-AYY

Fawaz Muhmud Ali Nasser (Nasser) and Muhammad Kamal al-Ayy (al-Ayy) provide financial, material, technological support, financial or other services to or in support of, HAMAS.

As of mid-2018, Nasser, a Gaza-based HAMAS financial auditor, worked with Gaza-based money exchanger al-Ayy to transfer Iranian funds through Hizballah to HAMAS and Palestinian Islamic Jihad (PIJ), a designated FTO, SDGT, and SDT.  Nasser also managed funds related to HAMAS prisoners, including those in the Ofer prison.

As of late 2016, al-Ayy worked with a Gaza-based HAMAS financial facilitator to coordinate funds transfers to HAMAS.

SANCTIONS IMPLICATIONS

As a result of today’s action, all property and interests in property of these targets that are in the United States or in the possession or control of U.S. persons must be blocked and reported to OFAC.  OFAC’s regulations generally prohibit all dealings by U.S. persons or within the United States (including transactions transiting the United States) that involve any property or interests in property of blocked or designated persons.  In addition, persons that engage in certain transactions with the individuals designated today may themselves be exposed to sanctions or subject to an enforcement action. 

and the one for the financial firms:

PRESS RELEASES

Treasury Labels Bank Providing Financial Services to Hizballah as Specially Designated Global Terrorist

Washington – Today, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned Jammal Trust Bank SAL (Jammal Trust), a Lebanon-based financial institution that knowingly facilitates banking activities for Hizballah.  Specifically, OFAC designated Jammal Trust as a Specially Designated Global Terrorist (SDGT) pursuant to Executive Order (E.O.) 13224 for assisting in, sponsoring, or providing financial, material, or technological support for, or financial or other services to or in support of, Hizballah.  Jammal Trust has a longstanding relationship with a key Hizballah financial entity and provides financial services to Hizballah’s Executive Council and the Iran-based Martyrs Foundation.  As part of today’s action, OFAC also designated Jammal Trust’s Lebanon-based subsidiaries Trust Insurance S.A.L., Trust Insurance Services S.A.L., and Trust Life Insurance Company S.A.L., for being owned or controlled by Jammal Trust. 
 
“Treasury is targeting Jammal Trust Bank and its subsidiaries for brazenly enabling Hizballah’s financial activities.  Corrupt financial institutions like Jammal Trust are a direct threat to the integrity of the Lebanese financial system.  Jammal Trust provides support and services to Hizballah’s Executive Council and the Martyrs Foundation, which funnels money to the families of suicide bombers,” said Sigal Mandelker, Under Secretary for Terrorism and Financial Intelligence.  “The U.S. will continue to work with the Central Bank of Lebanon to deny Hizballah access to the international financial system.  This action is a warning to all who provide services to this terrorist group.”
 
Today’s action highlights how Hizballah continues to prioritize its interests, and those of its chief sponsor, Iran, over the welfare of Lebanese citizens and Lebanon’s economy.  We regret that Hizballah has brought hardship to the Shia community, in particular, and call upon the Lebanese Government to exert every effort to mitigate the impacts on innocent account holders who did not realize Hizballah was putting their savings at risk.  The United States is confident that the Central Bank of Lebanon and other Lebanese institutions, through their legal and regulatory policies and oversight functions, will continue to work to protect the stability and soundness of Lebanon’s financial system, which is critical to supporting a stable and prosperous economy.
 
The Department of State designated Hizballah as a Foreign Terrorist Organization in October 1997 and as a Specially Designated Global Terrorist (SDGT) pursuant to E.O. 13224 in October 2001.  Hizballah was first 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.
 
JAMMAL TRUST BANK SAL
 
Jammal Trust assists in, sponsors, or provides financial, material, or technological support for, or financial or other services to or in support of, Hizballah.
 
Jammal Trust knowingly facilitates the banking activities of U.S.-designated entities openly affiliated with Hizballah, Al-Qard al-Hassan and the Martyrs Foundation, in addition to services it provides to Hizballah’s Executive Council.  Hizballah has used accounts at Jammal Trust to pay its operatives and their families, and Jammal Trust has actively attempted to conceal its banking relationship with numerous wholly owned Martyrs Foundation subsidiaries.  When opening purportedly “personal accounts” at Jammal Trust, Al-Qard al-Hassan officials clearly identified themselves to Jammal Trust as senior members of the terrorist group.  Jammal Trust then facilitated these accounts to be used to conduct business on Al-Qard al-Hassan’s behalf.  Such a scheme is representative of the deep coordination between Hizballah and Jammal Trust, which dates back to at least the mid-2000s and which spans many of the bank’s branches in Lebanon.  Also, Hizballah Member of Parliament Amin Sherri coordinates Hizballah’s financial activity at Jammal Trust with the bank’s management.  OFAC designated Amin Sherri in July 2019 for acting for or on behalf of Hizballah pursuant to E.O. 13224.
 
The Treasury Department designated the Martyrs Foundation, including its U.S. branch, and Al-Qard al-Hassan, under E.O. 13224 in July 2007.  The Martyrs Foundation is an Iranian parastatal organization that channels financial support from Iran to several terrorist organizations in the Levant, including Hizballah and the Palestinian Islamic Jihad (PIJ).  Martyrs Foundation branches in Lebanon have also provided financial support to the families of killed or imprisoned Hizballah and PIJ members, including suicide bombers in the Palestinian territories.  Additionally, Hizballah used Al-Qard al-Hassan as a cover to manage its financial activity, and it has assumed a prominent role in Hizballah’s financial infrastructure.
 
TRUST INSURANCE S.A.L.
 
OFAC designated Trust Insurance S.A.L. (Trust Insurance) for being owned or controlled by Jammal Trust.
 
In 2001, Trust Insurance and Trust Life Insurance Company S.A.L. became members of the Jammal Trust group, to provide standard insurance products to individuals and institutional clients.  Trust Insurance, which was established in 1996, is a subsidiary of Jammal Trust and is 99.42% owned by the bank. 
 
TRUST INSURANCE SERVICES S.A.L.
 
OFAC designated Trust Insurance Services S.A.L. (Trust Insurance Services) for being owned or controlled by Jammal Trust.
 
Trust Insurance Services, which was established in 2012, is a subsidiary of Jammal Trust and is 90% owned by the bank.
 
TRUST LIFE INSURANCE COMPANY S.A.L. 
 
OFAC designated Trust Life Insurance Company S.A.L. (Trust Life) for being owned or controlled by Jammal Trust.
 
Trust Life, which provides life insurance services, was established in 2001.  Trust Life and Trust Insurance products are backed by Jammal Trust.  Moreover, Trust Life is a subsidiary of Jammal Trust and is 99.56% owned by the bank. 
 
SANCTIONS IMPLICATIONS
 
The Treasury Department continues to prioritize disruption of the full range of Hizballah’s illicit financial activity.  With this action, OFAC has designated over 50 Hizballah-affiliated individuals and entities since 2017.
 
As a result of today’s sanctions, all property and interests in property of these targets that are in the United States or in the possession or control of U.S. persons must be blocked and reported to OFAC.  OFAC’s regulations generally prohibit all dealings by U.S. persons or within the United States (including transactions transiting the United States) that involve any property or interests in property of blocked or designated persons.  In addition, persons that engage in certain transactions with the individuals and entities designated today may themselves be exposed to sanctions or subject to an enforcement action. 
 
The four entities designated today are further subject to secondary sanctions pursuant to the Hizballah Financial Sanctions Regulations, which implements the Hizballah International Financing Prevention Act of 2015, as amended by the Hizballah International Financing Prevention Amendments Act of 2018.  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.
 

Links:

OFAC Notice

State Department Press Releases – Individuals, Entities

Treasury Department Press Releases – Individuals, Entities

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