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5/2/2024

Treasury Targets Sanctions Evaders Supporting Key Hizballah Financial Advisor | U.S. Department of the Treasury

Treasury Targets Sanctions Evaders Supporting Key Hizballah
Financial Advisor
May 2, 2024

WASHINGTON — Today, the U.S. Department of the Treasuryʼs O ice of Foreign Assets
Control (OFAC) designated five individuals for helping U.S.-designated Hizballah money
exchanger Hassan Moukalled (Moukalled) and his company, CTEX Exchange, evade sanctions
and facilitate illicit activities in support of Hizballah. These individuals, including two cofounders of CTEX Exchange and two of Moukalledʼs sons, operate two companies in Lebanon
and the United Arab Emirates (UAE) that are being concurrently designated. Individuals and
entities targeted today are being designated pursuant to Executive Order (E.O.) 13224, as
amended, which targets terrorist groups, their supporters, and those who aid acts of
terrorism.
“Hizballah continues to rely on seemingly legitimate business investments and key facilitators
to generate revenue for the groupʼs operations, including its destabilizing attacks across
Israelʼs northern border,” said Under Secretary of the Treasury for Terrorism and Financial
Intelligence Brian E. Nelson. “The United States remains focused on relentlessly pursuing
Hizballahʼs key revenue sources and constraining its ability to further destabilize the region.”
This action builds on OFACʼs January 24, 2023 designations of Moukalled, his companies CTEX
Exchange, Lebanese Company for Information and Studies SARL (LCIS), and Lebanese
Company for Publishing, Media, and Research, as well as Rayyan Hassan Moukalled (Rayyan
Moukalled) and Rani Hassan Moukalled (Rani Moukalled) pursuant to E.O. 13224, as amended.
The UAE added the same three individuals and CTEX Exchange to their Local Terrorist List in
February 2023.
Moukalled continues to serve as a financial advisor to Hizballah and works closely with senior
Hizballah finance o icials, including U.S.-designated Muhammad Qasir, to represent
Hizballahʼs business interests throughout the Middle East. Moukalled, jointly with Hizballah
senior o icials Muhammad Qasir and Muhammad Qasim al-Bazzal, established CTEX Exchange
as a financial facilitation front company for Hizballah. OFAC designated Muhammad Qasir
and Muhammad Qasim al-Bazzal pursuant to E.O. 13224 for acting for or on behalf of
Hizballah on May 15, 2018 and November 20, 2018, respectively.
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Treasury Targets Sanctions Evaders Supporting Key Hizballah Financial Advisor | U.S. Department of the Treasury

HIZB ALLAH ADVISOR MOUKALLEDʼS SANCT IONS EVASION
NET W ORK
Adnan Mahmoud Youssef (Youssef) is an employee of CTEX Exchange and has, as of mid2023, sought investors to set up companies in the UAE on behalf of Moukalled in
circumvention of the sanctions imposed on Moukalled in early 2023 by the government of the
UAE. Youssef has been involved in business dealings, including discussions of proposals and
profitability, with Rayyan Moukalled and Rani Moukalled. Additionally, Youssef has engaged in
business transactions with and received over a million dollars from U.S.-designated Hizballah
financier Mohammad Ibrahim Bazzi.
Mazen Hassan al-Zein (al-Zein) is a UAE-based business consultant for Moukalled. As
recently as mid-2023, al-Zein has been a business partner with Moukalled and Youssef on
various projects in the UAE. Al-Zein also had management role in a parent company that
would administer a number of businesses the three men planned to establish in the UAE on
Moukalledʼs behalf following Moukalledʼs designation. Moukalled appointed al-Zein as his
representative to coordinate with Moukalledʼs associates on his behalf, particularly on
business deals with potential investors to secure millions of dollarsʼ worth of funds.
Al-Zein is the Chief Executive O icer (CEO) and founder of The Crystal Group, a Lebanon and
UAE-based hospitality company.
Youssef and al-Zein are being designated for having acted or purported to act for or on behalf
of, directly or indirectly, Moukalled, a person whose property and interests in property are
blocked pursuant to E.O. 13224, as amended. The Crystal Group is being designated for being
owned, controlled, or directed by, directly or indirectly, al-Zein, a person whose property and
interests in property are blocked pursuant to E.O. 13224, as amended.
Andriyah Samir Mushantaf (Mushantaf) and Bashir Ibrahim Mansur (Mansur), jointly with
Moukallad, contributed capital towards founding CTEX Exchange. Mushantaf and Mansur
continue to be minority shareholders in CTEX Exchange alongside Moukalled.
Mushantaf and Mansur 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, CTEX Exchange, a person whose property and interests
in property are blocked pursuant to E.O. 13224, as amended.
Moukalled o en involves his family members in illicit activities for Hizballah, including his
previously designated children, Rayyan and Rani. Firas Hasan Moukalled (Firas), Moukalledʼs
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Treasury Targets Sanctions Evaders Supporting Key Hizballah Financial Advisor | U.S. Department of the Treasury

son, is also involved in Moukalledʼs business dealings through U.S.-designated LCIS, where
Firas works. Lebanon-based Teleport Company SAL (Teleport) is jointly owned and operated
by Mushantaf and two of Moukalledʼs sons, Firas and Rayyan.
Firas is 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, Moukalled, a person whose property and interests in property are blocked
pursuant to E.O. 13224, as amended. Teleport is being designated pursuant to E.O. 13224, as
amended, for being owned, controlled, or directed by, directly or indirectly, Mushantaf, Firas,
and Rayyan, persons whose property and interests in property are blocked pursuant to E.O.
13224, as amended.

SANCT IONS IMPLICAT IONS
As a result of todayʼs action, all property and interests in property of the designated 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, OFACʼs 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.
Furthermore, engaging in certain transactions with persons designated today entails risk of
secondary sanctions pursuant to E.O. 13224, as amended. Individuals and entities being
designated today are also subject 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 these
authorities, 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 of a foreign financial
institution that knowingly conducted or facilitated any significant transaction on behalf of a
Specially Designated Global Terrorist, or, among other things, knowingly facilitates a
significant transaction for Hizballah or certain persons designated for their connection to
Hizballah.
In addition, non-U.S. financial institutions and other persons that engage in certain
transactions or activities with sanctioned entities and individuals may expose themselves to
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Treasury Targets Sanctions Evaders Supporting Key Hizballah Financial Advisor | U.S. Department of the Treasury

sanctions risk or be subject to an enforcement action. The prohibitions include the making of
any contribution or provision of funds, goods, or services by, to, or for the benefit of any
designated person, or the receipt of any contribution or provision of funds, goods, or services
from any such person.
The power and integrity of OFAC sanctions derive not only from OFACʼs 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 OFACʼs Frequently Asked
Question 897 here. For detailed information on the process to submit a request for removal
from an OFAC sanctions list, please click here.
Treasury remains committed to enabling the flow of legitimate humanitarian assistance
supporting the basic human needs of vulnerable populations, while continuing to deny
resources to malicious actors. Accordingly, OFAC sanctions programs contain provisions for
legitimate humanitarian support to vulnerable populations, including authorizations for
certain humanitarian transactions in support of nongovernmental organizationsʼ activities.
For more information, please review relevant authorizations and guidance on OFACʼs website.
Click here to view identifying information on the individuals and entities designated today.
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