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OFAC Issues Lebanon Sanctions Regulations

The Office of Foreign Assets Control has issued a final rule, effective July 30, 2010, which adds a new Part 549 to 31 CFR to implement the Lebanon Sanctions Regulations.

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Regs Block Property of Persons Determined to Undermine Lebanon Sovereignty

OFAC is issuing these regulations in order to implement Executive Order 13441, “Blocking Property of Persons Undermining the Sovereignty of Lebanon or Its Democratic Processes and Institution,” which blocks all property and interests in property in the U.S., that hereafter come within the U.S. or within the possession or control of any U.S. person, including any overseas branch, of certain persons who undermine the sovereignty of Lebanon or its democratic processes or institutions.

Specifically, new 31 CFR 549.201(a) blocks any person determined by the Secretary of the Treasury (in consultation with the Secretary of State):

“(1) To have taken, or to pose a significant risk of taking, actions, including acts of violence, that have the purpose or effect of undermining Lebanon's democratic processes or institutions, contributing to the breakdown of the rule of law in Lebanon, supporting the reassertion of Syrian control or otherwise contributing to Syrian interference in Lebanon, or infringing upon or undermining Lebanese sovereignty;

(2) To have materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services in support of, the activities described in paragraph (a)(1) of this section, including acts of violence, or any person whose property and interests in property are blocked pursuant to this paragraph (a);

(3) To be a spouse or dependent child of any person whose property and interests in property are blocked pursuant to this paragraph (a); or

(4) To be owned or controlled by, or acting or purporting to act for or on behalf of, directly or indirectly, any person whose property and interests in property are blocked pursuant to this paragraph (a).”

(OFAC notes that the names of blocked persons are published on OFAC’s Specially Designated Nationals and Blocked Persons List.)

In addition, new 31 CFR 549.411 states that the property and interests in property of an entity which owns, directly or indirectly, a 50 percent or greater interest of an entity whose property and interests in property are blocked pursuant to 15 CFR 549.201(a) are also blocked, regardless of whether the entity itself is designated pursuant to 31 CFR 549.201(a).

Transactions Prohibited by Lebanon Sanctions Regulations

New 31 CFR 549.201(b) prohibits on the following transactions involving persons blocked under the Lebanon Sanctions Regulations:

“(1) The making of any contribution or provision of funds, goods, or services by, to, or for the benefit of any person whose property and interests in property are blocked pursuant to paragraph (a) of this section; and

(2) The receipt of any contribution or provision of funds, goods, or services from any person whose property and interests in property are blocked pursuant to paragraph (a) of this section.”

(See OFAC’s final rule for complete Lebanon Sanctions Regulations.

See ITT’s Online Archives or 08/07/07 news, 07080799 #6, for BP summary of EO 13441.)

OFAC’s SDN List is available here.

OFAC contact -- Assistant Director for Compliance, Outreach & Implementation (202) 622-2490

(FR Pub 07/30/10)