The US Department of Treasury’s Office of Foreign Assets Control recently designated Raymond Zina Rahme and Teddy Zina Rahme, two Lebanese brothers who allegedly used their power, wealth, and companies under their control to engage in corrupt practices in order to enrich themselves at the expense of their fellow citizens. According to OFAC, the bothers secured a subcontract with the Lebanese government to import fuel in 2017. Under that contract, the brothers allegedly imported tainted fuel that caused significant harm to Lebanese power plants – fuel that caused power stations across Lebanon to malfunction and daily electricity cuts to increase. OFAC reports that the brothers engaged in this scheme at a time when Lebanon is experiencing a dire energy crisis and its people are facing significant economic distress.
OFAC designated the brothers pursuant to Executive Order 13441, which authorizes sanctions against persons that pose a significant risk of undermining Lebanon’s democratic processes or institutions or contributing to the breakdown of the rule of law in Lebanon. OFAC also designated three companies owned or managed by the brothers, including ZR Energy DMCC, a United Arab Emirates-based company allegedly responsible for attempting to disguise the tainted fuel product by blending it with other fuels.
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 designated persons. In addition, entities owned 50 percent or more by one or more designated persons are also blocked.