Thursday, September 27, 2012


The assertion, by both US and Lebanese officials, that the designated global terrorist organisation Hezbollah is increasing its support to the Government of Syria, equals double trouble for compliance officers at international banks whose clients trade with Lebanese businesses.

It is already high risk to facilitate international trade with Lebanon, in those instances where it is likely that the goods or services your bank clients is providing to Lebanese companies is destined to Hezbollah, as the end user. Now, one must factor in the additional danger that Hezbollah is itself shipping those goods directly to the beleaguered Assad regime, whose access is severely limited, due to international sanctions in place against Syria, due to the war crimes being inflicted upon the civilian population by the military, security forces, and militia.

Therefore, it is prudent that you demand, and receive, written assurances that the end users of your clients' goods and services be specifically named, preferably in a sworn affidavit, and that the document state that the sales are not for resale or shipment to any sanctioned entity or individual. This may not go over too well with long term clients engaged in international trade, but the alternative is major exposure to possible sanctions, fines, penalties, and reputation damage.


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