OFAC Sanctions Lebanese, DRC Money Launderers, Issues Three FAQs
The Treasury’s Office of Foreign Assets Control sanctioned three people involved in money laundering in Lebanon and the Democratic Republic of the Congo as well as 17 entities and one vessel, Treasury said in a Dec. 13 press release. OFAC also issued three new counterterrorism-related frequently asked questions.
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OFAC targeted Lebanon-based Nazem Said Ahmad, one of Hizballah’s top donors, and DRC-based Saleh Assi, who launders money through Ahmad’s diamond business, Treasury said. The sanctions also apply to Ahmad’s “vast art collection,” OFAC said, which may be in the possession of U.S. people or companies. The agency also sanctioned Lebanon-based accountant Tony Saab, who provides support to Assi, and Assi’s yacht, the Flying Dragon.
Ahmad owns 11 Lebanese companies that are being sanctioned: Beirut Diam SAL, Beirut Gem SAL, Debbiye 143 SAL, Damour 850 SAL, Gebaa 2480 SAL, Noumayriye 1057 SAL, and Nour Holding SAL, Montecarlo Beach SAL, Beirut Trade SAL, and Blue Star Diamond SAL and Aramoun 1506 SAL. OFAC said the 11 companies “should not be viewed as an exhaustive list” of Ahmad’s companies and the “regulated company” is responsible for “conducting necessary due diligence” under OFAC’s 50 percent rule, which sanctions any entity owned 50 percent or more by Ahmad.
OFAC also sanctioned Assi’s companies: Minocongo, Pain Victoire, Trans Gazelle, Inter Aliment SAL, Al Yumun Real Estate Company SAL and Salasko Offshore S.A.L.
In FAQ 812, OFAC said U.S. companies and people are blocked from engaging in transactions involving information, including “artwork,” that is subject to people designated as Specially Designated Global Terrorists. OFAC said the prohibition extends to “artwork and other information and information materials,” but there are certain exemptions under the International Emergency Economic Powers Act relating to “personal communications, humanitarian donations, information or informational materials, and travel.” The prohibition applies to not only all people or companies in the U.S. but also to U.S.-incorporated entities and their foreign branches. Non-U.S. people who engage in these prohibited actions subject to U.S. jurisdiction may be subject to civil or criminal penalties, OFAC said. Foreign banks may also be subject to “correspondent and payable through account sanctions” if they knowingly engage in “significant transactions” on behalf of a SDGT.
In FAQ 813, OFAC said “galleries, museums, private art collectors, auction companies, and others” involved in selling artwork must ensure they do not violate these sanctions. The agency said they should develop a “tailored, risk-based compliance program,” including risk screening programs. “An adequate compliance solution will depend on a variety of factors,” OFAC said, “including the type of business involved, and there is no single compliance program or solution suitable for every circumstance.” Non U.S. persons, including foreign banks, who violate these sanctions may be subject to civil or criminal penalties.
In FAQ 814, OFAC said that people or companies that are in possession of artwork that is the property of an SDGT must ensure the artwork is “denied” to the SDGT. Art holders must also ensure compliance with OFAC regulations related to blocked assets, including restrictions on the sale of the art to third parties. Blocked property must be reported to OFAC within 10 business days, the agency said.