In coordinated actions on August 11, 2023, the United States, the United Kingdom, and Canada designated Riad Salameh, former governor of the Banque du Liban, the central bank of Lebanon.
In the United States, Salameh and four close associates were designated pursuant to Executive Order 13441 – Salameh for taking actions that undermine Lebanon’s democratic processes and the others for having materially assisted or supported Salameh’s actions. According to Office of Foreign Assets Control of the US Department of the Treasury (OFAC), Salameh exploited his position as governor of the bank to engage in self-enrichment schemes involving shell companies and bank accounts in Europe and the Caribbean. Salameh’s brother, Raja Salameh, also designated, is said to have used a British Virgin Islands shell company to divert hundreds of millions of dollars from transactions with the bank, facilitated by Riad. Others designated for their participation in the same scheme are Marianne Hoayek, Anna Kosakova, and Nady Salameh; the former worked at the bank with Salameh, whilst Kosakava and Nady Salameh had personal and familial relationships with Salameh. Their roles, as described by OFAC, were as officers or owners of companies that laundered the illicit profits through the purchase of real estate in Europe.
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 per cent or more by one or more blocked persons are also blocked.
The UK designations impose travel bans and asset freezes on Riad Salameh, his brother Raja, Hoayek and Kosakova. The designations, made pursuant to the Global Anti-Corruption Sanctions Regulations 2021, are the first ever imposed against individuals involved in corruption in Lebanon. In a statement accompanying the designations, the UK Minister of State for the Middle East said, “the only way to put Lebanon on the path to much-needed economic recovery is for its leaders to stamp out corruption and implement real reforms.”
Neither the US nor the UK sanctions extend to the Banque du Liban or its US and UK correspondent banks.
Simultaneously with the US and UK actions, the government of Canada designated Riad and Raja Salameh and Marianne Hoayek pursuant to the Justice for Victims of Corrupt Foreign Officials Act (Sergei Magnitsky Law), resulting in asset freezes and travel bans.