Tuesday, March 3, 2015


Pro-Hezbollah parade in Nigeria.

The OFAC sanctions imposed recently, against expat Lebanese in Nigeria, who were providing material support to Hezbollah, means that there is a valid risk you are unwittingly banking overseas Lebanese who are working with, and supporting that specially designated global terrorist organization. Can you accurately profile possible Hezbollah members ? Hezbollah reportedly is operating in 45 countries, including 11 in Africa.

Let us take a quick look at the Nigerian case; the individuals who were sanctioned:

(1) Were wealthy Lebanese businessmen working and living in Africa. This is not an unusual occurrence.
(2) Reportedly hid weapons inside their amusement park; they also owned a supermarket, which is coincidentally a cash-intensive business.
(3) Were probably have been involved in the attempted covert importation of weapons into Nigeria, which was seized by Nigerian authorities while in transit.
(4) Maintained an armory in the city of Kano.

Exactly how does one determine whether specific Lebanese expats who are working in your country, and banking with you, have a high probability of being associated with Hezbollah ?

(A) We can probably eliminate those Lebanese expats, who are second- or third- generation locals with little or no ties to their country of origin.
(B) We can also rule out Lebanese who are Christians.
(C) We should include any Lebanese who are Shiite Muslims, as are Hezbollah.
(D) Was the individual born in Lebanon, and a naturalized citizen of your country ? That was the case with the sanctioned persons in Nigeria. Does he have multiple passports/citizenships ?
(E) Does the individual engage in international travel, though his business does not seem to require it ? Has he been to Beirut more than once a year ?
(F) Does the individual seem to be pious, with respect to his practice of his religion ?
(G) Is he sending "profits" back to Lebanon ?

You may want to take a close look, unannounced and in the field, at his stated business or occupation. Is it genuine, or does it appear to possibly be a front ? I would rather that you identify any Hezbollah operators early on, before a terrorist attack occurs, and your bank is named as the facilitator of funding that operation, or of sending money to Hezbollah's global headquarters in Beirut. The Nigerian contingent, who identified other Hezbollah agents working in Nigeria, intended to attack Western and/or Israeli targets; The financial and reputational damage arising out of negative publicity surrounding any banks involved, even indirectly, in such acts cannot be measured.

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