On April 18, 2023, the Department of the Treasury’s Office of Foreign Assets Control designated 52 members of a network that facilitated transactions on behalf of Hizballah financier and Specially Designated Global Terrorist Nazem Said Ahmad (“Ahmad”), who was sanctioned by the US in 2019 for providing material support to Hizballah. The fifty-two persons designated in this action reside in Lebanon, the United Arab Emirates, South Africa, Angola, Côte d’Ivoire, the Democratic Republic of the Congo, Belgium, the UK and Hong Kong. The designations were issued pursuant to Executive Order 13224, as amended, which targets terrorists, their organizations, leaders and supporters. OFAC’s action was taken in coordination with the US Department of Homeland Security, the US Department of State’s Rewards for Justice program, and authorities in the UK.
According to OFAC, the network is largely comprised of Ahmad’s family members, associates, and companies that utilize the permissive global diamond, precious gems, and art market to pay for, ship and deliver luxury goods for Ahmad. The network also allegedly uses aliases, false paperwork, and front companies to purchase high-priced luxury goods for Ahmad and then leverages Hizballah’s influence at certain ports to import the goods into Lebanon without paying applicable taxes and duties. Among the designees is Ahmad’s wife Rima Baker as well as companies that she owns or controls. OFAC alleges that Baker has served as a proxy for the purchase and consignment of art in Ahmad’s collection. OFAC also designated Ahmad’s son Firas Ahmad and two diamond companies that he controls; Ahmad’s daughter Hind Ahmad and two galleries that she owns and controls; and Hind’s husband who has allegedly facilitated transactions for his wife and her galleries. Other designees include Ahmad’s accountants Sundar Nagarajan, Ali Mossalem and Mohamad Ismail, who allegedly facilitated payments and coordinated logistics related to the shipment of Ahmad’s art into Lebanon.
As a result of these designations, all property and interests in property of the designees within the United States or within the possession or control of a US person are blocked, and US persons are generally prohibited from engaging in transactions involving the designated persons. In addition, entities owned 50 percent or more by a designated person or entity are also blocked, and foreign financial institutions that knowingly conduct significant transactions for the designated entities risk exposure to sanctions.