The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) yesterday designated 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, Türkiye, 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).
Yesterday’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 yesterday, 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.
The Treasury department alleges that the “courier network” operates between Lebanon, Turkey, the United Arab Emirates and Iran to move cash outside the formal financial system, allowing Hezbollah to obtain foreign currency and evade sanctions.
Treasury identified Turkish businessman Yunus Alper Yilmaz as the network’s manager. It said he uses certain Turkey-based exchange houses as “fronts for his business dealings” and provides front companies and bank accounts for money transfers linked to Iran’s Islamic Revolutionary Guard Corps-Quds Force.
The department said couriers collect cash from the exchange houses and covertly transport it on commercial flights, including to Lebanon, where Hezbollah is based.
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 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, 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 yesterday’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.
The Trump OFAC also re-designated Hezbollah a “specially designated global terrorist”, citing what the treasury department described as the IRGC Quds Force’s coordination of Hezbollah attacks and its deep involvement in shaping the group’s political decisions.
A state department spokesperson, Tommy Pigott, tied the action to Washington’s broader campaign against Tehran.
He said: “The network uses couriers traveling on commercial airline flights between Lebanon, Turkey, the UAE and Iran to move hundreds of millions of dollars, enabling the regime to obtain foreign currency illicitly, evade sanctions and fund Hezbollah.”
He added that the investigation leading to the sanctions was carried out in coordination with Turkish authorities, and said the US would continue targeting networks that finance Hezbollah’s activities against Lebanon’s sovereignty and regional security.
Here is the complete list of entities covered by the sanctions:
HIZBALLAH (a.k.a. ANSAR ALLAH; a.k.a. EXTERNAL SECURITY ORGANIZATION OF HEZBOLLAH; a.k.a. FOLLOWERS OF THE PROPHET MUHAMMED; a.k.a. HIZBALLAH ESO; a.k.a. HIZBALLAH INTERNATIONAL; a.k.a. ISLAMIC JIHAD; a.k.a. ISLAMIC JIHAD FOR THE LIBERATION OF PALESTINE; a.k.a. ISLAMIC JIHAD ORGANIZATION; a.k.a. LEBANESE HEZBOLLAH; a.k.a. LEBANESE HIZBALLAH; a.k.a. ORGANIZATION OF RIGHT AGAINST WRONG; a.k.a. ORGANIZATION OF THE OPPRESSED ON EARTH; a.k.a. PARTY OF GOD; a.k.a. REVOLUTIONARY JUSTICE ORGANIZATION; a.k.a. "ESO"; a.k.a. "EXTERNAL SECURITY ORGANIZATION"; a.k.a. "EXTERNAL SERVICES ORGANIZATION"; a.k.a. "FOREIGN ACTION UNIT"; a.k.a. "FOREIGN RELATIONS DEPARTMENT"; a.k.a. "FRD"; a.k.a. "LH"; a.k.a. "SPECIAL OPERATIONS BRANCH"); Additional Sanctions Information - Subject to Secondary Sanctions Pursuant to the Hizballah Financial Sanctions Regulations; Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886 [FTO] [SDGT]. -to- HIZBALLAH (a.k.a. ANSAR ALLAH; a.k.a. EXTERNAL SECURITY ORGANIZATION OF HEZBOLLAH; a.k.a. FOLLOWERS OF THE PROPHET MUHAMMED; a.k.a. HIZBALLAH ESO; a.k.a. HIZBALLAH INTERNATIONAL; a.k.a. ISLAMIC JIHAD; a.k.a. ISLAMIC JIHAD FOR THE LIBERATION OF PALESTINE; a.k.a. ISLAMIC JIHAD ORGANIZATION; a.k.a. LEBANESE HEZBOLLAH; a.k.a. LEBANESE HIZBALLAH; a.k.a. ORGANIZATION OF RIGHT AGAINST WRONG; a.k.a. ORGANIZATION OF THE OPPRESSED ON EARTH; a.k.a. PARTY OF GOD; a.k.a. REVOLUTIONARY JUSTICE ORGANIZATION; a.k.a. "ESO"; a.k.a. "EXTERNAL SECURITY ORGANIZATION"; a.k.a. "EXTERNAL SERVICES ORGANIZATION"; a.k.a. "FOREIGN ACTION UNIT"; a.k.a. "FOREIGN RELATIONS DEPARTMENT"; a.k.a. "FRD"; a.k.a. "LH"; a.k.a. "SPECIAL OPERATIONS BRANCH"); Additional Sanctions Information - Subject to Secondary Sanctions Pursuant to the Hizballah Financial Sanctions Regulations; Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886; Organization Type: Transnational Terrorist Group [FTO] [SDGT] [IRGC] [IFSR] (Linked To: ISLAMIC REVOLUTIONARY GUARD CORPS (IRGC)-QODS FORCE).
