On 3 July 2025, the US Treasury's Office of Foreign Assets Control (OFAC), acting jointly with the other member states of the Terrorist Financing Targeting Center (TFTC), designated five entities and sixteen individuals forming the core of Hizballah's financial infrastructure, under Executive Order 13224 as amended. Newly designated entities include Tashilat SARL (a Lebanese lender that provided loans on behalf of Hizballah and operated as part of Al-Qard Al-Hassan (AQAH) and Bayt al-Mal), alongside senior AQAH officials Samer Hasan Fawaz and Ali Mohamad Karnib. The action reaffirms and expands sanctions on AQAH, Hizballah's shadow "benevolent loan association" bank, and Bayt al-Mal, its unofficial treasury, both previously designated by OFAC in 2007 and 2006 respectively. It is the ninth TFTC joint designation since the center's creation in May 2017 and the third under this Administration; designated persons are alleged to have moved over $500 million through the formal Lebanese banking system — including US-designated Jammal Trust Bank — via joint and shadow accounts despite existing sanctions.

Analyst notesShow

Mechanism

Joint TFTC (Terrorist Financing Targeting Center — a US-Gulf coalition formed in 2017 to coordinate counter-terror-finance designations) action, executed domestically by OFAC under E.O. 13224 as amended. The designation targets the operating layer around AQAH and Bayt al-Mal rather than the institutions themselves (both already under sanction since 2006-2007): Tashilat SARL is named as a loan-making vehicle that channeled funds on Hizballah's behalf, and Samer Hasan Fawaz / Ali Mohamad Karnib are named as AQAH's administrative and procurement heads respectively — Karnib specifically for overseeing purchase of over 1,000 ounces of gold for AQAH as of July 2024. The press release also re-describes existing designees (Yazbeck, Nehme Ahmad Jamil, Abbas Hassan Gharib, Mustafa Habib Harb) as Tashilat's joint owners/controllers, formally looping the new entity into the pre-existing sanctions web via ownership/control theory rather than a fresh substantive violation.

Effect: all property and interests in property of the designated persons within US jurisdiction or held by US persons are blocked; US persons are generally prohibited from transacting with them. Designation is immediate upon OFAC's SDN List update (no wind-down period, consistent with GTSR/E.O. 13224 terrorism designations rather than sectoral determinations).

Downstream implications

Reinforces the ownership/control theory OFAC uses to reach entities structurally distinct from

already-sanctioned parents (AQAH, Bayt al-Mal) — a template likely to recur as Hizballah continues re-registering financial vehicles to route around blocks.

Signals continued US Treasury focus on Hizballah's post-2024-conflict financial reconstruction

channels, following the 2024 destruction of much of Bayt al-Mal's physical infrastructure.

Any Lebanese or regional bank found processing transactions for the newly designated network

(particularly successor accounts to the already-sanctioned Jammal Trust Bank) faces secondary- sanctions exposure.

Open questions

Whether TFTC partner states (Gulf Cooperation Council members) mirror the designation

domestically, and on what timeline.

Scale of Tashilat SARL's loan book and whether further associated entities are identified in

follow-on OFAC actions.

Sources

Primary: OFAC Recent Actions — Counter Terrorism Designations (2025-07-03) · US Treasury press release — Terrorist Financing Targeting Center Jointly Designates Hizballah Financial Institutions and Senior Officials

Secondary: Global Trade Alert — Sanctions imposed on Hizballah-controlled financial institution

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Mechanism

Downstream implications

Reinforces the ownership/control theory OFAC uses to reach entities structurally distinct from

already-sanctioned parents (AQAH, Bayt al-Mal) — a template likely to recur as Hizballah continues re-registering financial vehicles to route around blocks.

Signals continued US Treasury focus on Hizballah's post-2024-conflict financial reconstruction

channels, following the 2024 destruction of much of Bayt al-Mal's physical infrastructure.

Any Lebanese or regional bank found processing transactions for the newly designated network

(particularly successor accounts to the already-sanctioned Jammal Trust Bank) faces secondary- sanctions exposure.