Monday, June 17, 2013


The announcement, by the Gulf Cooperation Council (GCC), declaring that its member states shall impose sanctions upon Hezbollah, for providing military support to the Assad regime, will result in a realignment of the routes that the terrorist organisation uses to funnel criminal proceeds to its Beirut headquarters. You should be alert for the sudden appearance of new pipelines for Hezbollah narco-profits, lest you unwittingly facilitate these transfers, and pay for it later with regulatory fines & penalties, imposed by the GCC or the United States.

The GCC sanctions are specific; they involve:

(1) Hezbollah and Hezbollah loyalists.
(2) Their residences.
(3) Their financial and business transactions.

If you have clients who have been regularly remitting funds to any of the six GCC countries: Saudi Arabia, Bahrain, Qatar, Kuwait, Oman, and the UAE, and the wire transfer instructions have been amended, to send all payments to Lebanon, forthwith, you may be seeing Hezbollah transfers taking a new, more direct, path home. The original path, through a low-risk GCC Middle East country, is now no longer safe or acceptable, due to the Council's new policies about Hezbollah.

Ask these questions:

(A) Are there regular payments, and are they substantial ?
(B) Was the change in beneficiary abrupt, and effective immediately ?
(C) What is the reason that the client has cited for the change in instructions ?

If you are a compliance officer at an international bank whose clients trade regularly with the Middle East, brief your bank staff to notify you forthwith, should any client suddenly shift payments to Lebanon.

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