OFAC Lebanon sanctions

The U.S. Office of Foreign Assets Control (OFAC), housed within the Treasury Department, administers several sanctions authorities that touch Lebanon. Unlike comprehensive embargoes on countries such as Cuba or Iran, the Lebanon-related measures are targeted — they focus on specific individuals, entities, and networks rather than the Lebanese state or economy as a whole.

The principal authorities include:

• Executive Order 13441 (2007), issued by President George W. Bush, which blocks the property of persons determined to undermine Lebanon's sovereignty, democratic processes, or institutions, including those contributing to instability via Syria.
• The Hizballah Financial Sanctions Regulations (HFSR), implementing the Hizballah International Financing Prevention Act (HIFPA) of 2015 and its 2018 amendments, which require sanctions on foreign financial institutions that knowingly facilitate significant transactions for Hizballah.
• Executive Order 13224 (2001) on counterterrorism, used to designate Hizballah officials, financiers, and affiliated companies as Specially Designated Global Terrorists (SDGTs).
• Executive Order 13818 (2017), implementing the Global Magnitsky Act, used to sanction Lebanese officials for corruption — most notably the September 2020 designation of former minister Ali Hassan Khalil and MP Yusuf Finyanus.

Practical effects of being placed on OFAC's Specially Designated Nationals (SDN) List include freezing of any U.S.-jurisdiction assets, a prohibition on transactions by U.S. persons, and significant secondary sanctions risk for non-U.S. banks. The latter has made Lebanese commercial banks highly cautious about correspondent relationships, contributing to compliance-driven de-risking even before Lebanon's 2019 financial collapse.

OFAC issues General Licenses and FAQs clarifying permissible humanitarian and remittance activity, and parties may seek removal through the agency's delisting process. Designations are coordinated with the State Department and, where relevant, with EU and UK Treasury counterparts, though U.S. and European lists do not fully overlap — notably regarding whether Hizballah's "political wing" is sanctioned.