WASHINGTON—Today, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) is designating 10 individuals that are part of a network responsible for transferring cash to Hizballah. The network utilizes couriers travelling on commercial airline flights between Lebanon, Turkiye, the UAE, and Iran to move up to hundreds of millions of dollars between jurisdictions, providing an avenue outside the formal financial system for Hizballah to obtain foreign currency and evade sanctions. OFAC is also re-designating Hizballah for service to the Iranian regime under the command of Iran’s Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF).
Today’s action is being taken pursuant to the United States’ counterterrorism authority, Executive Order (E.O.) 13224, as amended. The U.S. Department of State designated Hizballah as a Specially Designated Global Terrorist (SDGT) pursuant to E.O. 13224 on October 31, 2001, for having committed, or posing a significant risk of committing, acts of terrorism that threaten the security of U.S. nationals or the national security, foreign policy, or economy of the United States. Previously, the U.S. Department of State had designated Hizballah as a Foreign Terrorist Organization (FTO) pursuant to section 219 of the Immigration and Nationality Act on October 8, 1997. OFAC designated the IRGC-QF as an SDGT pursuant to E.O. 13224 on October 25, 2007, for providing material support to multiple terrorist organizations, including Hizballah. The U.S. Department of State designated the IRGC-QF as an FTO pursuant to section 219 of the Immigration and Nationality Act on April 8, 2019.
Hizballah’S courier network
Hizballah and its allies exploit financing schemes including oil smuggling, illicit shipping, commodities sales, and bulk cash smuggling to generate and move funds across the region. The network targeted today, which was once associated with now-deceased IRGC-QF finance official Behnam Shahriyari, is one example of the methods used to funnel support to terrorist proxy groups throughout the region.
Turkish businessman Yunus Alper Yilmaz (Yilmaz) manages the network of couriers responsible for moving cash between other countries in the region and Hizballah’s base in Lebanon. Yilmaz abuses certain Türkiye-based exchange houses as fronts for his business dealings and provided front companies and bank accounts for money transfers connected with the IRGC-QF. Yilmaz’s associates include couriers Halil Ibrahim Kacmaz and Onder Dede who collect cash from the exchange houses, and Vasfi Akyuz who has coordinated logistics for the couriers and also participates as a courier himself. Additional couriers in the network include Mehmet Akyuz, Mehmet Acur, Feyyad Karasalih, Masoud Mousafar, Gulay Kaya Savci, and Emrah Ayaz, who have covertly carried cash intended for Hizballah on commercial flights to Lebanon.
Yunus Alper Yilmaz, Halil Ibrahim Kacmaz, and Onder Dede arebeing designated pursuant to E.O. 13224, as amended, for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, the IRGC-QF. Vasfi Akyuz, Mehmet Akyuz, Mehmet Acur, Feyyad Karasalih, Masoud Mousafar, Gulay Kaya Savci, and Emrah Ayaz are being designated pursuant to E.O. 13224, as amended, for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, Hizballah.
Additionally, based on the IRGC-QF’s coordination of Hizballah attacks, and deep involvement in directing Hizballah’s political decision-making, Hizballah is being re-designated pursuant to E.O. 13224, as amended, for being owned, controlled, or directed by, or having acted or purported to act for or on behalf of, the IRGC-QF.
SANCTIONS IMPLICATIONS
As a result of today’s action, all property and interests in property of the designated or blocked persons described above that are in the United States or in the possession or control of U.S. persons are blocked and must be reported to OFAC. In addition, any entities that are owned, directly or indirectly, individually or in the aggregate, 50 percent or more by one or more blocked persons are also blocked. Unless authorized by a general or specific license issued by OFAC, or exempt, OFAC’s regulations generally prohibit all transactions by U.S. persons or within (or transiting) the United States that involve any property or interests in property of designated or otherwise blocked persons.
Violations of U.S. sanctions may result in the imposition of civil or criminal penalties on U.S. and foreign persons. OFAC may impose civil penalties for sanctions violations on a strict liability basis. OFAC’s Economic Sanctions Enforcement Guidelines provide more information regarding OFAC’s enforcement of U.S. economic sanctions. In addition, financial institutions and other persons may risk exposure to sanctions for engaging in certain transactions or activities involving designated or otherwise blocked persons. The prohibitions include the making of any contribution or provision of funds, goods, or services by, to, or for the benefit of any designated or blocked person, or the receipt of any contribution or provision of funds, goods, or services from any such person. Non-U.S. persons are also prohibited from causing or conspiring to cause U.S. persons to wittingly or unwittingly violate U.S. sanctions, as well as engaging in conduct that evades U.S. sanctions. Individuals located in the United States or abroad who provide information about sanctions violations to FinCEN’s whistleblower incentive program may be eligible for awards if the information they provide leads to a successful enforcement action that results in monetary penalties exceeding $1,000,000.
Furthermore, engaging in certain transactions involving the persons designated today may risk the imposition of secondary sanctions on participating foreign financial institutions. OFAC can prohibit or impose strict conditions on opening or maintaining, in the United States, a correspondent account or a payable-through account of a foreign financial institution that knowingly conducts or facilitates any significant transaction on behalf of a person who is designated pursuant to the relevant authority.
The power and integrity of OFAC sanctions derive not only from OFAC’s ability to designate and add persons to the SDN List, but also from its willingness to remove persons from the SDN List consistent with the law. The ultimate goal of sanctions is not to punish, but to bring about a positive change in behavior. For information concerning the process for seeking removal from an OFAC list, including the SDN List, please refer to OFAC’s Frequently Asked Question 897 here and to submit a request for removal, click here.
Click here for more information on the persons designated today.
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