Tuesday, November 15, 2011


Expatriate Lebanese Shia, who are sending funds to Hezbollah from overseas, represent a potential problem for compliance officers at Western Hemisphere banks. The United States, Mexico, Venezuela, Argentina, Brazil, Paraguay, and Colombia all have a number of ethnic Lebanese, some of who are Shiite Muslims who contribute financially to Hezbollah.

There have been a number of arrests in the United States, as well as in Latin America, of Hezbollah operatives and financiers, but there is also the danger that legitimate Lebanese businessmen, who are supporters of Hezbollah, are using your bank to fund a specially designated global terrorist organisation. We are talking about a possible criminal charge of Providing Financial Support to a Terrorist Organisation.

Thus, whilst you should not profile all Lebanese bank clients as potential terrorist financiers, you may want to consider the following measures:

(1) Search your records for all your Lebanese bank clients who regularly send funds to Beirut.

(2) Eliminate all purely commercial ongoing matters, where value is actually exchanged in international trade. There may be some that can only be ruled out through Enhanced Due Diligence.

(3) Eliminate small remittances that appear to be to family members.

(4) Regarding the remaining clients, do any of the wire transfers go to banks known to be owned or controlled by Hezbollah ? Do you now need to file suspicious Activity Reports (SARS) ?

Take your results, and after performing Enhanced Due Diligence enquiries, have your board of directors make a command decision on closing some, or all, of the accounts. You may want to seek the advice of outside bank counsel at this point.

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