Notice of Finding That Halawi Exchange Co. Is a Financial Institution of Primary Money Laundering Concern, 24596-24599 [2013-09785]
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24596
Federal Register / Vol. 78, No. 80 / Thursday, April 25, 2013 / Notices
This money launderer continued to wire
large dollar amounts to U.S.-based car
dealers via a Rmeiti Exchange account
prior to the LCB 311 Action.
Rmeiti Exchange facilitated money
laundering for other entities engaged in
trade-based money laundering. Rmeiti
processed over $3 million in dozens of
large, round-dollar international wire
transfers to two entities, whose
businesses engaged in transactions
typical of used-car trade-based money
laundering. The two entities received
over $2 million in wire transfers for car
purchases from entities in high-risk
trade-based money laundering regions,
including through another exchange
house.
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2. Rmeiti Exchange Actively Seeks
Money Laundering Opportunities With
Other Lebanese Exchange Houses and
Precious Metal Dealers
Rmeiti Exchange owner Kassem
Rmeiti has also worked with other
Lebanese exchange houses, including
Halawi Exchange, determined to be a
financial institution operating outside of
the United States that is of primary
money laundering concern on April 22,
2013, to facilitate money laundering
activities. For example, Rmeiti
Exchange, Halawi Exchange, and other
exchange houses sent over $9 million in
dozens of round-number, largedenomination international wire
transfers from unknown sources to the
same U.S. car shipping business from
2007 through 2010. Rmeiti Exchange
and Halawi Exchange have facilitated
financial activity on behalf of a money
launderer involved in collecting illicit
drug proceeds. Kassem Rmeiti has
worked with a separate Lebanese
exchange house to coordinate currency
transfers and courier shipments on
behalf of various money launderers
between mid-2011 and mid-2012.
Benin-based suspected money launderer
Kassem Rmeiti, the owner of Rmeiti
Exchange, continues to actively seek
money laundering opportunities in
trade transactions. For example, Rmeiti
sought the assistance of a Lebanonbased money launderer in April 2012, to
begin selling African gold in Lebanon or
Dubai. Rmeiti Exchange and its owners’
and employees’ willingness to work for
a variety of criminal networks involved
in drug trafficking and money
laundering suggests that a venture into
the import or export of gold, which is
a high-risk industry for money
laundering, will likely provide another
source to commingle illicit funds for Ali
Mohamed Kharroubi and others.
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C. Rmeiti Exchange Facilitates or
Promotes Money Laundering for
Specially Designated Global Terrorist
Hizballah
Rmeiti Exchange has also conducted
money laundering activities for and
provided financial services to Hizballah.
Rmeiti Exchange used accounts it held
at LCB to deposit bulk cash shipments
generated by Hizballah through illicit
activity in Africa and as of December
2011, Hizballah had replaced U.S.designated Elissa Exchange owner Ali
Kharroubi with Haitham Rmeiti—the
manager/owner of STE Rmeiti—as a key
facilitator for wiring money and
transferring Hizballah funds. Rmeiti
Exchange, through its owner, Kassem
Rmeiti, owns Societe Rmaiti SARL
(a.k.a. STE Rmeiti). These steps taken by
Hizballah demonstrate its efforts to
adapt after U.S. Government disruptive
action, and illustrates the need for
continued action against its financial
facilitators.
IV. The Extent to Which This Action Is
Sufficient To Guard Against
International Money Laundering and
Other Financial Crimes
FinCEN’s April 22, 2013 finding that
Rmeiti Exchange is an institution of
primary money laundering concern,
along with the Special Measures
proposed pursuant to the Finding and
published elsewhere in this issue of the
Federal Register, will guard against
international money laundering and
other financial crimes directly by
restricting the ability of Rmeiti
Exchange to access the U.S. financial
system to process transactions, and
indirectly by public notification to the
international financial community of
the risks posed by dealing with Rmeiti
Exchange.
Dated: April 20, 2013.
Jennifer Shasky Calvery,
Director, Financial Crimes Enforcement
Network.
[FR Doc. 2013–09783 Filed 4–23–13; 11:15 am]
BILLING CODE 4810–02–P
DEPARTMENT OF THE TREASURY
Financial Crimes Enforcement Network
Notice of Finding That Halawi
Exchange Co. Is a Financial Institution
of Primary Money Laundering Concern
Financial Crimes Enforcement
Network, Treasury (‘‘FinCEN’’).
ACTION: Notice of finding.
AGENCY:
This document provides
notice that the Director of FinCEN found
on April 22, 2013, that Halawi Exchange
SUMMARY:
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Co. (‘‘Halawi Exchange’’) is a financial
institution operating outside the United
States that is of primary money
laundering concern.
DATES: The finding referred to in this
notice was effective as of April 22, 2013.
FOR FURTHER INFORMATION CONTACT:
FinCEN, (800) 949–2732.
SUPPLEMENTARY INFORMATION:
I. Statutory Provisions
On October 26, 2001, the President
signed into law the Uniting and
Strengthening America by Providing
Appropriate Tools Required to Intercept
and Obstruct Terrorism Act of 2001 (the
‘‘USA PATRIOT Act’’), Public Law 107–
56. Title III of the USA PATRIOT Act
amends the anti-money laundering
provisions of the Bank Secrecy Act
(‘‘BSA’’), codified at 12 U.S.C. 1829b, 12
U.S.C 1951–1959, and 31 U.S.C. 5311–
5314, 5316–5332, to promote the
prevention, detection, and prosecution
of international money laundering and
the financing of terrorism. Regulations
implementing the BSA appear at 31 CFR
Chapter X. The authority of the
Secretary of the Treasury (the
‘‘Secretary’’) to administer the BSA and
its implementing regulations has been
delegated to the Director of FinCEN.
Section 311 of the USA PATRIOT Act
(‘‘Section 311’’), codified at 31 U.S.C.
5318A, grants the Secretary the
authority, upon finding that reasonable
grounds exist for concluding that a
foreign jurisdiction, financial
institution, class of transaction, or type
of account is of ‘‘primary money
laundering concern,’’ to require
domestic financial institutions and
financial agencies to take certain
‘‘special measures’’ to address the
primary money laundering concern.
II. The Extent to Which Halawi
Exchange Is Used for Legitimate
Business Purposes in Lebanon
A. Halawi Exchange
Halawi Exchange offers a variety of
financial services, primarily currency
exchange and transmission of funds.
Halawi Exchange, along with other
related entities, is organized under a
holding company known as Halawi
Holding SAL, which also owns several
other related companies in Lebanon.
The Halawi companies are based in
Beirut, Lebanon, share key corporate
leadership, maintain offices at the same
addresses, share common phone
numbers and common email addresses,
and frequently reference their close
connection to one another. They are also
regularly displayed together on
corporate signage and on public
materials, one of which shows them
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collectively under a banner which reads
‘‘Collaboration Under One Thumb.’’
Available information suggests that
Halawi Exchange, in addition to the
activities of concern discussed below,
engages in other, unremarkable
transactions of a type, volume, and
variety typical of Lebanese exchange
houses or brokerages. If these services
were offered to U.S. customers and if
they took place wholly or substantially
in the United States, the Halawi
Exchange would be treated as a
financial institution under the BSA,
defined at 31 CFR 1010.100(t)(3).
Specifically, Halawi Exchange offer
services that would be defined as money
transmission, activities defined at 31
CFR 1010.100(ff), in addition to other
services it may offer.
Halawi Exchange identifies itself as ‘‘a
family business under the Halawi
group.’’ In 2012, Halawi Exchange
expanded to cover five branches in
Lebanon and a sister company in
London under the name ‘‘Halawi
Exchange Co. LTD.’’ It lists its partners
as Mahmoud Halawi and Ali Halawi
who, according to Halawi Exchange,
maintain ‘‘daily involvement in
management and operations of the
company.’’ Halawi Exchange also
advertises that it operates in the Sudan,
United Arab Emirates, Saudi Arabia,
Qatar, Kuwait, Bahrain, Jordan, the
United Kingdom, and Australia.
Mahmoud Halawi is the sole or
majority owner and senior management
officer at Halawi Exchange, Halawi
Holding SAL, and Halawi Investment
Trust SAL. He is also President of the
Money Changers Association in
Lebanon. His son, Fouad Halawi, is a
Director at Halawi Holding SAL and has
served as a manager at Halawi
Exchange.
B. Lebanon
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Lebanon is a financial hub for banking
activities in the Middle East and eastern
Mediterranean and has a sophisticated
banking sector.1 There are 72 banks
operating in Lebanon,2 and all major
banks have correspondent relationships
with U.S. financial institutions. The five
largest commercial banks account for an
estimated 61% of total banking assets
for the country, which are estimated at
$95 billion.3 The government retains no
1 ‘‘2012 International Narcotics Control Strategy
Report (‘INCSR’),’’ Bureau of International Narcotics
and Law Enforcement Affairs, The Department of
State, March 7, 2012, www.state.gov/g/inl/rls/
nrcrpt/2010/vol2/137212.htm).
2 ‘‘Complete List of Operating Banks in Lebanon,’’
Banque du Liban (www.bdl.gov.lb). www.bdl.gov.lb
/bfs/CB/index.htm as of 1/30/2013.
3 Estimated from values in the ‘‘2012 Investment
Climate Statement—Lebanon,’’ Bureau of Economic
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18:10 Apr 24, 2013
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direct ownership of any commercial
banks and maintains an indirect
ownership stake in one bank.4 Despite
slowed economic growth following
domestic political instability and
regional turmoil in 2011, Lebanon’s
banking sector continues to rely on
significant capital inflows from the
Lebanese diaspora community,5 which
has been a large contributor to banking
sector liquidity and capitalization,
estimated by the World Bank at $7.6
billion—18% of GDP—in 2011.6 Banks’
exposure to the heavily-indebted
sovereign, with total government debt
projected at 132% of GDP in 2012,
remains a significant risk to stability
and growth of the financial sector.7
Money exchange businesses became a
major feature of Lebanon’s financial
sector during the Lebanese civil war and
have played a key role in providing
services such as international funds
transfers, currency conversion, and
payments and deposits for domestic and
expatriate Lebanese clientele since
1990. In 2001, Lebanon’s Central Bank,
Banque du Liban (‘‘BdL’’), published a
set of circulars expanding regulations
for exchange houses operating in the
country.8 Since the enactment of the
2001 law, 732 money exchange
businesses have registered with BdL,
and currently there are 374 active
licensed businesses.9 Each of these
active licensed businesses must process
payments through business accounts
established in Lebanese banks.10
Lebanon also faces money laundering
and terrorist financing vulnerabilities 11
due to weaknesses in its Anti-Money
Laundering/Combating the Financing of
and Business Affairs, June 2012 Report.
www.state.gov/e/eb/rls/othr/ics/2012/191182.htm.
4 ‘‘2012 Index of Economic Freedom,’’ The
Heritage Foundation. https://www.heritage.org/index
/country/lebanon.
5 ‘‘2012 Investment Climate Statement—
Lebanon,’’ Bureau of Economic and Business
Affairs, The Department of State, June 2012 Report.
www.state.gov/e/eb/rls/othr/ics/2012/191182.htm.
6 The latest available World Bank data estimated
in November 2012 that remittances were $7.6bn for
2012. ‘‘Remittances Data: Inflows,’’ Migration and
Remittances, The World Bank, November 2012.
https://econ.worldbank.org/WBSITE/EXTERNAL/
EXTDEC/EXTDECPROSPECTS/0,,contentMDK:2112
1930∼menuPK:3145470∼pagePK:64165401∼pi
PK:64165026∼theSitePK:476883,00.html.
7 ‘‘IMF Executive Board Concludes 2011 Article
IV Consultation with Lebanon Public Information
Notice (PIN) No. 12/11, ‘‘International Monetary
Fund, February 8, 2012. https://www.imf.org/
external/np/sec/pn/2012/pn1211.htm.
8 BdL, Law 347 Regulating the Money Changer
Profession in Lebanon, August 6, 2001.
9 BdL, List of Exchange Institutions, May 2012,
https://www.bdl.gov.lb/bfs/MS/Money_Dealers_
arabic.pdf.
10 BdL, Intermediate BdL Circular 264, dated May
21, 2011, pages 3–4, https://www.bdl.gov.lb/circ/
intpdf/int264_en.pdf.
11 2012 INCSR.
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Terrorism (‘‘AML/CFT’’) regime, porous
borders, ineffective and inconsistent
regulation, and a challenging and
complex domestic and regional political
and security environment, among other
factors. Of concern is the possibility that
a portion of the substantial flow of
remittances could be associated with
trade-based money laundering and other
illicit finance activities. For example,
Lebanon imposes currency reporting
requirements on banks and money
exchange businesses that undertake
cross-border cash and precious metal
activity,12 but has no corresponding
cross-border declaration requirement for
the public at Lebanese points of entry,
resulting in a significant cash-smuggling
vulnerability.
These vulnerabilities have been
recently exploited to support tradebased money laundering. FinCEN
identified Lebanese Canadian Bank
(‘‘LCB’’) as an institution of primary
money laundering concern in February
2011 (the ‘‘LCB 311 Action’’),13 which
was preceded by the Office of Foreign
Assets Control’s (‘‘OFAC’s’’) designation
of Lebanese Ayman Joumaa as a
Specially Designated Narcotics
Trafficker (‘‘SDNT’’), as well as of three
Lebanon-based money exchange
businesses used by Ayman Joumaa and
his organization to launder illicit
proceeds, Elissa Exchange Company,
Hassan Ayash Exchange, and New Line
Exchange Trust Co., under the Foreign
Narcotics Kingpin Act Designation in
January 2011.14 In the LCB 311 Action,
FinCEN determined that LCB was
facilitating the money laundering
activities of the Joumaa drug trafficking
and money laundering network. This
network moved illegal drugs from South
America to Europe and the Middle East
via West Africa and laundered hundreds
of millions of dollars monthly through
accounts held at LCB, as well as through
trade-based money laundering involving
consumer goods throughout the world,
including through used car dealerships
in the United States. Further, the LCB
311 Action exposed the terrorist
organization Hizballah’s links to LCB
and that Hizballah derived financial
12 Special Investigation Commission,
Intermediate BdL Circular 263, dated May 21, 2011,
https://www.sic.gov.lb/circular263.shtml.
13 FinCEN, Finding That the Lebanese Canadian
Bank SAL Is a Financial Institution of Primary
Money Laundering Concern, 76 F.R. 9403, dated
February 17, 2011, https://www.gpo.gov/fdsys/pkg/
FR-2011-02-17/pdf/2011-3346.pdf.
14 Press Release, ‘‘Treasury Targets Major
Lebanese-Based Drug Trafficking and Money
Laundering Network,’’ 1/26/11, https://
www.treasury.gov/press-center/press-releases/
Pages/tg1035.aspx; Additions to OFAC’s SDN list,
dated January 26, 2011, https://www.treasury.gov/
resource-center/sanctions/OFAC-Enforcement/
Pages/20110126.aspx.
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support from criminal activities of
Joumaa’s network.
Following these Treasury actions, two
U.S. Attorney’s Offices took actions
against Ayman Joumaa, Elissa Exchange,
and Hassan Ayash Exchange. In
December 2011, a grand jury in the
Eastern District of Virginia returned an
indictment against Ayman Joumaa for
conspiracy to distribute narcotics and
conspiracy to commit money laundering
related to drug trafficking by Mexican
and Colombian drug cartels.15 In August
2012, the U.S. Attorney’s Office for the
Southern District of New York
(‘‘SDNY’’) seized $150 million as part of
a civil money laundering and forfeiture
action against Hizballah-linked LCB,
Elissa Exchange, and Hassan Ayash
Exchange based on money laundering
schemes involving Ayman Joumaa, the
exchange houses, and U.S. car dealers.16
The ‘‘SDNY Complaint’’ listed, by name,
30 U.S. car dealers and a U.S. shipping
company that facilitated the scheme.
BdL re-evaluated AML/CFT
regulations regarding money exchange
businesses following the Treasury
actions. In May and August 2011, BdL
revised Lebanon’s AML/CFT regulations
regarding supervised banks and other
non-bank financial institutions by
publishing seven decisions 17 modifying
Law 347 (dated August 6, 2001). BdL
required all of these active licensed
money exchangers to maintain business
accounts at a formal financial
institution, such as a registered
Lebanese bank subject to BdL
supervision, and prohibited exchangers
from operating accounts at Lebanese
banks on behalf of their clients.18
Despite some improvements to its
financial sector supervision, Lebanon
still has not acceded to the UN
Convention for the Suppression of the
Financing of Terrorism. And Hizballah,
an organization which the United States
designated as a Foreign Terrorist
Organization in October 1997 and a
Specially Designated Global Terrorist
under Executive Order 13224 in October
15 The United States Attorney’s Office for the
Eastern District of Virginia Press Release, ‘‘U.S.
Charges Alleged Lebanese Drug Kingpin With
Laundering Drug Proceeds For Mexican And
Colombian Drug Cartels’’ December 13, 2011,
https://www.justice.gov/usao/vae/news/2011/12/
20111213joumaanr.html.
16 The United States Attorney’s Office for the
Southern District of New York press release and
civil complaint.
17 In May 2011 Intermediate Decisions 10725,
10726 and 10728 and in August 2011 Intermediate
Decisions 10787, 10789, 10791, and 10792 were
published regarding AML/CFT regulations of
exchange businesses.
18 BdL, Intermediate BdL Circular 264, dated May
21, 2011, pages 3–4, https://www.bdl.gov.lb/circ/
intpdf/int264_en.pdf.
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2001,19 is a recognized political party
with an active role in the Lebanese
government. Though it has adopted
laws domestically criminalizing any
funds resulting from the financing, or
contribution to the financing, of
terrorism,20 the active participatory role
of a designated terrorist group in the
Lebanese government and civil society
calls into question the broader efficacy
of Lebanon’s AML/CFT regime.
III. The Extent to Which Halawi
Exchange and Its Subsidiaries Have
Been Used To Facilitate or Promote
Money Laundering in or Through
Lebanon
According to information available to
the U.S. Government, Halawi Exchange,
its subsidiaries, and their respective
management, ownership, and key
employees are engaged in illicit
financial activity. A pattern of regular,
round-number, large-denomination
international wire transfers consistent
with money laundering are processed
through Halawi Exchange. Many of
these transactions appear to be
structured because they are separated
into multiple smaller transactions for no
apparent reason. Halawi Exchange
facilitates transactions as part of a largescale trade-based money laundering
scheme that involves the purchase of
used cars in the United States for export
to West Africa. Additionally, Halawi
Exchange, and its management,
ownership, and key employees are
complicit in providing money
laundering services for an international
narcotics trafficking and money
laundering network that is affiliated
with Hizballah.
A. Past and Current Association With
Used Car Trade-Based Money
Laundering Scheme
Halawi Exchange facilitates
transactions for a network of individuals
and companies which launder money
through the purchase and sale of used
cars in the United States for export to
West Africa. In support of this network,
management, ownership, and key
employees of Halawi Exchange
coordinate transactions—processed
within and outside of Halawi
19 Hizballah is a Lebanon-based terrorist group.
Until September 11, 2001, Hizballah was
responsible for more American deaths than any
other terrorist organization.
20 For additional information about Lebanon’s
legal framework and special mechanisms for antimoney laundering and terrorist financing measures,
see The Middle East and North Africa Financial
Task Force (MENAFATF) Mutual Evaluation
Report, Lebanese Republic, November 10, 2009
(www.menafatf.org).
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Exchange—on behalf of Benin-based
money launderers and their associates.
A significant portion of the funds are
intended for U.S.-based car dealerships
for the purchase of cars which are then
shipped to Benin.
As of late 2012, Halawi Exchange was
primarily used by Benin-based Lebanese
car lot owners to wire transfer money to
their U.S. suppliers. The proceeds of car
sales were hand-transported in the form
of bulk cash U.S. dollars from Cotonou,
Benin to Beirut, Lebanon via air travel
and deposited directly into one of the
Halawi Exchange offices, which allowed
bulk cash deposits to be made without
requiring documentation of where the
money originated. Halawi Exchange,
through its network of established
international exchange houses, initiated
wire transfers to the United States
without using the Lebanese banking
system in order to avoid scrutiny
associated with Treasury’s designations
of Hassan Ayash Exchange, Elissa
Exchange, and its LCB 311 Action. The
money was wire transferred indirectly
to the United States through countries
that included China, Singapore, and the
UAE, which were perceived to receive
less scrutiny by the U.S. Government.
Participants in this network have
coordinated the movement of millions
of dollars per month, a significant
portion of which has moved through
Halawi Exchange. For example, in early
2012, Halawi Exchange, its
management, its ownership, or key
employees were involved in arranging
multiple wire transfers totaling over $4
million on behalf of this network.
Additionally, as of mid-2012, central
figures in this scheme planned to move
$224 million worth of vehicle shipping
contracts through this network via a
Halawi-owned Benin-based car lot,
which receives vehicle shipments from
the United States. Mahmoud Halawi
was heavily involved in the
establishment of this car lot, which is
run by Ahmed Tofeily, a Benin-based
money launderer, and continues to be
involved in its operations. This car lot
was established six months after the
SDNY Complaint. Additionally,
Tofeily—a Halawi agent/employee—
owns and operates a car lot in Benin
named Auto Deal (AKA Ste Auto Deal,
Societe Auto Deal) which purchases
cars in Canada and exports them
through the United States. Tofeily
worked closely with Halawi Exchange
and wired all of his money through it.
This car lot—identified as maintaining
no brick and mortar structures—has
wired hundreds of thousands of dollars
throughout 2012 from Benin to U.S.based car dealerships.
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From 2008 to 2011, Halawi Exchange,
its management, and employees sent
numerous international wire transfers to
U.S.-based used car companies
consistent with the practice of
laundering money through the purchase
of cars in the United States for export to
West Africa. Ali Halawi—a partner at
Halawi Exchange—is listed by name on
many of these transfers. A large number
of these transfers were sent through
accounts at LCB, which has been
identified by Treasury as a financial
institution of primary money laundering
concern under Section 311 for its role in
facilitating the money laundering
activities of Ayman Joumaa’s
international narcotics trafficking and
money laundering network. Some of the
U.S.-based car dealerships that received
funds transfers from Halawi Exchange
were later identified in the SDNY
Complaint as participants in the Joumaa
network’s money laundering activities.
Joumaa’s network moved illegal drugs
from South America to Europe and the
Middle East via West Africa and
laundered hundreds of millions of
dollars monthly through accounts held
at LCB, as well as through trade-based
money laundering involving consumer
goods throughout the world, including
through used car dealerships in the
United States. This criminal scheme
involved bulk cash smuggling
operations and use of several Lebanese
exchange houses that utilized accounts
at LCB branches, as discussed in the
LCB 311 Action.
Halawi Exchange has also worked
with other Lebanese exchange houses,
including Rmeiti Exchange, to facilitate
money laundering activities. For
example, Halawi Exchange, Rmeiti
Exchange, and other exchange houses
sent over $9 million in dozens of roundnumber, large-denomination
international wire transfers from
unknown sources to the same U.S. car
shipping business from 2007 through
2010.
B. Past and Current Connection to
Designated Narcotics Kingpins and
Their Associates
SDNTs Ibrahim Chebli and Abbas
Hussein Harb regularly coordinated and
executed financial transactions—
including bulk cash transfers—that were
processed through the Halawi Exchange.
Harb and Chebli were designated by
Treasury in June 2012 pursuant to the
Kingpin Act for collaboration with
Joumaa in the movement of millions of
dollars of narcotics-related proceeds.
Harb’s Columbia- and Venezuela-based
organization has laundered money for
the Joumaa network through the
Lebanese financial sector. Additionally,
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Chebli used his position as the manager
of the Abbassieh branch of Fenicia Bank
in Lebanon to facilitate the movement of
money for Joumaa and Harb.21
C. Past and Current Connection to
Another International Narcotics
Trafficking and Money Laundering
Network With Ties to Hizballah
Management and key employees at
Lebanon-based Halawi Exchange and
members of the Halawi family
coordinate, execute, receive, or are
otherwise involved in millions of
dollars worth of transactions for
members of another international
narcotics trafficking and money
laundering network. For example, highlevel management at Lebanon-based
Halawi Exchange and members of the
Halawi family were involved in the
movement of over $4 million in late
2012 for this international narcotics
trafficking and money laundering
network. Additionally, Fouad Halawi,
acting in his capacity as a senior official
at Halawi Holding, was responsible for
the receipt and transfer of funds for this
narcotics trafficking and money
laundering network and provided
accounting services for its senior
leadership. To avoid detection, the
involved parties scheduled structured
payments by splitting larger sums into
smaller, more frequent transactions
which they often moved through
numerous high-risk jurisdictions.
This additional international
narcotics trafficking and money
laundering network has been involved
in extensive international narcotics
trafficking operations. For example, it is
known to have trafficked heroin from
Lebanon to the United States and
hundred-kilogram quantities of cocaine
from South America to Nigeria for
distribution in Europe and Lebanon. It
is also known to have trafficked cocaine
out of Lebanon in multi-ton quantities.
The head of this network has operated
an extensive money laundering
organization, including a series of
offshore corporate shell companies and
underlying bank accounts, established
by intermediaries, to receive and send
money transfers throughout the world. It
has arranged the laundering of profits
from large-scale narcotics trafficking
operations. Transfers coordinated by
this network have impacted the United
States, Canada, Europe, the Middle East,
Asia, Australia, and South America.
This international narcotics trafficking
21 Exhibit 25—Press Release, ‘‘Treasury Targets
Major Money Laundering Network Linked to Drug
Trafficker Ayman Joumaa and a Key Hizballah
Supporter in South America,’’ 6/27/11, https://
www.treasury.gov/press-center/press-releases/
Pages/tg1624.aspx
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24599
and money laundering network is
affiliated with Hizballah.
Additionally, Halawi Exchange is
known to have laundered profits from
drug trafficking and cocaine-related
money laundering for a Hizballah leader
and narcotics trafficker. Halawi
Exchange has also been routinely used
by other Hizballah associates as a means
to transfer illicit funds.
IV. The Extent to Which This Action Is
Sufficient To Guard Against
International Money Laundering and
Other Financial Crimes
FinCEN’s April 22, 2013, notice of
finding that Halawi Exchange is an
institution of primary money laundering
concern, along with the Special
Measures simultaneously proposed
pursuant to the Finding, will guard
against the international money
laundering and other financial crimes
described above directly by restricting
the ability of Halawi Exchange to access
the U.S. financial system to process
transactions, and indirectly by public
notification to the international
financial community of the risks posed
by dealing with Halawi Exchange.
Dated: April 20, 2013.
Jennifer Shasky Calvery,
Director, Financial Crimes Enforcement
Network.
[FR Doc. 2013–09785 Filed 4–23–13; 11:15 am]
BILLING CODE 4810–02–P
DEPARTMENT OF THE TREASURY
Financial Crimes Enforcement Network
Order Imposing Recordkeeping and
Reporting Obligations on Certain U.S.
Financial Institutions With Respect to
Transactions Involving Kassem Rmeiti
& Co. for Exchange as a Financial
Institution of Primary Money
Laundering Concern
Financial Crimes Enforcement
Network, Treasury (‘‘FinCEN’’).
ACTION: Order.
AGENCY:
The Director of FinCEN found
on April 22, 2013 that Kassem Rmeiti &
Co. For Exchange (‘‘Rmeiti Exchange’’)
is a financial institution operating
outside the United States that is of
primary money laundering concern. The
Director of FinCEN is issuing an order
imposing certain recordkeeping and
reporting obligations with respect to
transactions involving Rmeiti Exchange
(the ‘‘Order’’).
DATES: The Order was effective on April
23, 2013. The Order will remain in
effect until August 21, 2013.
SUMMARY:
E:\FR\FM\25APN2.SGM
25APN2
Agencies
[Federal Register Volume 78, Number 80 (Thursday, April 25, 2013)]
[Notices]
[Pages 24596-24599]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2013-09785]
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DEPARTMENT OF THE TREASURY
Financial Crimes Enforcement Network
Notice of Finding That Halawi Exchange Co. Is a Financial
Institution of Primary Money Laundering Concern
AGENCY: Financial Crimes Enforcement Network, Treasury (``FinCEN'').
ACTION: Notice of finding.
-----------------------------------------------------------------------
SUMMARY: This document provides notice that the Director of FinCEN
found on April 22, 2013, that Halawi Exchange Co. (``Halawi Exchange'')
is a financial institution operating outside the United States that is
of primary money laundering concern.
DATES: The finding referred to in this notice was effective as of April
22, 2013.
FOR FURTHER INFORMATION CONTACT: FinCEN, (800) 949-2732.
SUPPLEMENTARY INFORMATION:
I. Statutory Provisions
On October 26, 2001, the President signed into law the Uniting and
Strengthening America by Providing Appropriate Tools Required to
Intercept and Obstruct Terrorism Act of 2001 (the ``USA PATRIOT Act''),
Public Law 107-56. Title III of the USA PATRIOT Act amends the anti-
money laundering provisions of the Bank Secrecy Act (``BSA''), codified
at 12 U.S.C. 1829b, 12 U.S.C 1951-1959, and 31 U.S.C. 5311-5314, 5316-
5332, to promote the prevention, detection, and prosecution of
international money laundering and the financing of terrorism.
Regulations implementing the BSA appear at 31 CFR Chapter X. The
authority of the Secretary of the Treasury (the ``Secretary'') to
administer the BSA and its implementing regulations has been delegated
to the Director of FinCEN.
Section 311 of the USA PATRIOT Act (``Section 311''), codified at
31 U.S.C. 5318A, grants the Secretary the authority, upon finding that
reasonable grounds exist for concluding that a foreign jurisdiction,
financial institution, class of transaction, or type of account is of
``primary money laundering concern,'' to require domestic financial
institutions and financial agencies to take certain ``special
measures'' to address the primary money laundering concern.
II. The Extent to Which Halawi Exchange Is Used for Legitimate Business
Purposes in Lebanon
A. Halawi Exchange
Halawi Exchange offers a variety of financial services, primarily
currency exchange and transmission of funds. Halawi Exchange, along
with other related entities, is organized under a holding company known
as Halawi Holding SAL, which also owns several other related companies
in Lebanon. The Halawi companies are based in Beirut, Lebanon, share
key corporate leadership, maintain offices at the same addresses, share
common phone numbers and common email addresses, and frequently
reference their close connection to one another. They are also
regularly displayed together on corporate signage and on public
materials, one of which shows them
[[Page 24597]]
collectively under a banner which reads ``Collaboration Under One
Thumb.''
Available information suggests that Halawi Exchange, in addition to
the activities of concern discussed below, engages in other,
unremarkable transactions of a type, volume, and variety typical of
Lebanese exchange houses or brokerages. If these services were offered
to U.S. customers and if they took place wholly or substantially in the
United States, the Halawi Exchange would be treated as a financial
institution under the BSA, defined at 31 CFR 1010.100(t)(3).
Specifically, Halawi Exchange offer services that would be defined as
money transmission, activities defined at 31 CFR 1010.100(ff), in
addition to other services it may offer.
Halawi Exchange identifies itself as ``a family business under the
Halawi group.'' In 2012, Halawi Exchange expanded to cover five
branches in Lebanon and a sister company in London under the name
``Halawi Exchange Co. LTD.'' It lists its partners as Mahmoud Halawi
and Ali Halawi who, according to Halawi Exchange, maintain ``daily
involvement in management and operations of the company.'' Halawi
Exchange also advertises that it operates in the Sudan, United Arab
Emirates, Saudi Arabia, Qatar, Kuwait, Bahrain, Jordan, the United
Kingdom, and Australia.
Mahmoud Halawi is the sole or majority owner and senior management
officer at Halawi Exchange, Halawi Holding SAL, and Halawi Investment
Trust SAL. He is also President of the Money Changers Association in
Lebanon. His son, Fouad Halawi, is a Director at Halawi Holding SAL and
has served as a manager at Halawi Exchange.
B. Lebanon
Lebanon is a financial hub for banking activities in the Middle
East and eastern Mediterranean and has a sophisticated banking
sector.\1\ There are 72 banks operating in Lebanon,\2\ and all major
banks have correspondent relationships with U.S. financial
institutions. The five largest commercial banks account for an
estimated 61% of total banking assets for the country, which are
estimated at $95 billion.\3\ The government retains no direct ownership
of any commercial banks and maintains an indirect ownership stake in
one bank.\4\ Despite slowed economic growth following domestic
political instability and regional turmoil in 2011, Lebanon's banking
sector continues to rely on significant capital inflows from the
Lebanese diaspora community,\5\ which has been a large contributor to
banking sector liquidity and capitalization, estimated by the World
Bank at $7.6 billion--18% of GDP--in 2011.\6\ Banks' exposure to the
heavily-indebted sovereign, with total government debt projected at
132% of GDP in 2012, remains a significant risk to stability and growth
of the financial sector.\7\
---------------------------------------------------------------------------
\1\ ``2012 International Narcotics Control Strategy Report
(`INCSR'),'' Bureau of International Narcotics and Law Enforcement
Affairs, The Department of State, March 7, 2012, www.state.gov/g/inl/rls/nrcrpt/2010/vol2/137212.htm).
\2\ ``Complete List of Operating Banks in Lebanon,'' Banque du
Liban (www.bdl.gov.lb). www.bdl.gov.lb/bfs/CB/index.htm as of 1/30/
2013.
\3\ Estimated from values in the ``2012 Investment Climate
Statement--Lebanon,'' Bureau of Economic and Business Affairs, June
2012 Report. www.state.gov/e/eb/rls/othr/ics/2012/191182.htm.
\4\ ``2012 Index of Economic Freedom,'' The Heritage Foundation.
https://www.heritage.org/index/country/lebanon.
\5\ ``2012 Investment Climate Statement--Lebanon,'' Bureau of
Economic and Business Affairs, The Department of State, June 2012
Report. www.state.gov/e/eb/rls/othr/ics/2012/191182.htm.
\6\ The latest available World Bank data estimated in November
2012 that remittances were $7.6bn for 2012. ``Remittances Data:
Inflows,'' Migration and Remittances, The World Bank, November 2012.
https://econ.worldbank.org/WBSITE/EXTERNAL/EXTDEC/EXTDECPROSPECTS/
0,,contentMDK:21121930~menuPK:3145470~pagePK:64165401~piPK:64165026~t
heSitePK:476883,00.html.
\7\ ``IMF Executive Board Concludes 2011 Article IV Consultation
with Lebanon Public Information Notice (PIN) No. 12/11,
``International Monetary Fund, February 8, 2012. https://www.imf.org/external/np/sec/pn/2012/pn1211.htm.
---------------------------------------------------------------------------
Money exchange businesses became a major feature of Lebanon's
financial sector during the Lebanese civil war and have played a key
role in providing services such as international funds transfers,
currency conversion, and payments and deposits for domestic and
expatriate Lebanese clientele since 1990. In 2001, Lebanon's Central
Bank, Banque du Liban (``BdL''), published a set of circulars expanding
regulations for exchange houses operating in the country.\8\ Since the
enactment of the 2001 law, 732 money exchange businesses have
registered with BdL, and currently there are 374 active licensed
businesses.\9\ Each of these active licensed businesses must process
payments through business accounts established in Lebanese banks.\10\
---------------------------------------------------------------------------
\8\ BdL, Law 347 Regulating the Money Changer Profession in
Lebanon, August 6, 2001.
\9\ BdL, List of Exchange Institutions, May 2012, https://www.bdl.gov.lb/bfs/MS/Money_Dealers_arabic.pdf.
\10\ BdL, Intermediate BdL Circular 264, dated May 21, 2011,
pages 3-4, https://www.bdl.gov.lb/circ/intpdf/int264_en.pdf.
---------------------------------------------------------------------------
Lebanon also faces money laundering and terrorist financing
vulnerabilities \11\ due to weaknesses in its Anti-Money Laundering/
Combating the Financing of Terrorism (``AML/CFT'') regime, porous
borders, ineffective and inconsistent regulation, and a challenging and
complex domestic and regional political and security environment, among
other factors. Of concern is the possibility that a portion of the
substantial flow of remittances could be associated with trade-based
money laundering and other illicit finance activities. For example,
Lebanon imposes currency reporting requirements on banks and money
exchange businesses that undertake cross-border cash and precious metal
activity,\12\ but has no corresponding cross-border declaration
requirement for the public at Lebanese points of entry, resulting in a
significant cash-smuggling vulnerability.
---------------------------------------------------------------------------
\11\ 2012 INCSR.
\12\ Special Investigation Commission, Intermediate BdL Circular
263, dated May 21, 2011, https://www.sic.gov.lb/circular263.shtml.
---------------------------------------------------------------------------
These vulnerabilities have been recently exploited to support
trade-based money laundering. FinCEN identified Lebanese Canadian Bank
(``LCB'') as an institution of primary money laundering concern in
February 2011 (the ``LCB 311 Action''),\13\ which was preceded by the
Office of Foreign Assets Control's (``OFAC's'') designation of Lebanese
Ayman Joumaa as a Specially Designated Narcotics Trafficker (``SDNT''),
as well as of three Lebanon-based money exchange businesses used by
Ayman Joumaa and his organization to launder illicit proceeds, Elissa
Exchange Company, Hassan Ayash Exchange, and New Line Exchange Trust
Co., under the Foreign Narcotics Kingpin Act Designation in January
2011.\14\ In the LCB 311 Action, FinCEN determined that LCB was
facilitating the money laundering activities of the Joumaa drug
trafficking and money laundering network. This network moved illegal
drugs from South America to Europe and the Middle East via West Africa
and laundered hundreds of millions of dollars monthly through accounts
held at LCB, as well as through trade-based money laundering involving
consumer goods throughout the world, including through used car
dealerships in the United States. Further, the LCB 311 Action exposed
the terrorist organization Hizballah's links to LCB and that Hizballah
derived financial
[[Page 24598]]
support from criminal activities of Joumaa's network.
---------------------------------------------------------------------------
\13\ FinCEN, Finding That the Lebanese Canadian Bank SAL Is a
Financial Institution of Primary Money Laundering Concern, 76 F.R.
9403, dated February 17, 2011, https://www.gpo.gov/fdsys/pkg/FR-2011-02-17/pdf/2011-3346.pdf.
\14\ Press Release, ``Treasury Targets Major Lebanese-Based Drug
Trafficking and Money Laundering Network,'' 1/26/11, https://www.treasury.gov/press-center/press-releases/Pages/tg1035.aspx;
Additions to OFAC's SDN list, dated January 26, 2011, https://www.treasury.gov/resource-center/sanctions/OFAC-Enforcement/Pages/20110126.aspx.
---------------------------------------------------------------------------
Following these Treasury actions, two U.S. Attorney's Offices took
actions against Ayman Joumaa, Elissa Exchange, and Hassan Ayash
Exchange. In December 2011, a grand jury in the Eastern District of
Virginia returned an indictment against Ayman Joumaa for conspiracy to
distribute narcotics and conspiracy to commit money laundering related
to drug trafficking by Mexican and Colombian drug cartels.\15\ In
August 2012, the U.S. Attorney's Office for the Southern District of
New York (``SDNY'') seized $150 million as part of a civil money
laundering and forfeiture action against Hizballah-linked LCB, Elissa
Exchange, and Hassan Ayash Exchange based on money laundering schemes
involving Ayman Joumaa, the exchange houses, and U.S. car dealers.\16\
The ``SDNY Complaint'' listed, by name, 30 U.S. car dealers and a U.S.
shipping company that facilitated the scheme.
---------------------------------------------------------------------------
\15\ The United States Attorney's Office for the Eastern
District of Virginia Press Release, ``U.S. Charges Alleged Lebanese
Drug Kingpin With Laundering Drug Proceeds For Mexican And Colombian
Drug Cartels'' December 13, 2011, https://www.justice.gov/usao/vae/news/2011/12/20111213joumaanr.html.
\16\ The United States Attorney's Office for the Southern
District of New York press release and civil complaint.
---------------------------------------------------------------------------
BdL re-evaluated AML/CFT regulations regarding money exchange
businesses following the Treasury actions. In May and August 2011, BdL
revised Lebanon's AML/CFT regulations regarding supervised banks and
other non-bank financial institutions by publishing seven decisions
\17\ modifying Law 347 (dated August 6, 2001). BdL required all of
these active licensed money exchangers to maintain business accounts at
a formal financial institution, such as a registered Lebanese bank
subject to BdL supervision, and prohibited exchangers from operating
accounts at Lebanese banks on behalf of their clients.\18\
---------------------------------------------------------------------------
\17\ In May 2011 Intermediate Decisions 10725, 10726 and 10728
and in August 2011 Intermediate Decisions 10787, 10789, 10791, and
10792 were published regarding AML/CFT regulations of exchange
businesses.
\18\ BdL, Intermediate BdL Circular 264, dated May 21, 2011,
pages 3-4, https://www.bdl.gov.lb/circ/intpdf/int264_en.pdf.
---------------------------------------------------------------------------
Despite some improvements to its financial sector supervision,
Lebanon still has not acceded to the UN Convention for the Suppression
of the Financing of Terrorism. And Hizballah, an organization which the
United States designated as a Foreign Terrorist Organization in October
1997 and a Specially Designated Global Terrorist under Executive Order
13224 in October 2001,\19\ is a recognized political party with an
active role in the Lebanese government. Though it has adopted laws
domestically criminalizing any funds resulting from the financing, or
contribution to the financing, of terrorism,\20\ the active
participatory role of a designated terrorist group in the Lebanese
government and civil society calls into question the broader efficacy
of Lebanon's AML/CFT regime.
---------------------------------------------------------------------------
\19\ Hizballah is a Lebanon-based terrorist group. Until
September 11, 2001, Hizballah was responsible for more American
deaths than any other terrorist organization.
\20\ For additional information about Lebanon's legal framework
and special mechanisms for anti-money laundering and terrorist
financing measures, see The Middle East and North Africa Financial
Task Force (MENAFATF) Mutual Evaluation Report, Lebanese Republic,
November 10, 2009 (www.menafatf.org).
---------------------------------------------------------------------------
III. The Extent to Which Halawi Exchange and Its Subsidiaries Have Been
Used To Facilitate or Promote Money Laundering in or Through Lebanon
According to information available to the U.S. Government, Halawi
Exchange, its subsidiaries, and their respective management, ownership,
and key employees are engaged in illicit financial activity. A pattern
of regular, round-number, large-denomination international wire
transfers consistent with money laundering are processed through Halawi
Exchange. Many of these transactions appear to be structured because
they are separated into multiple smaller transactions for no apparent
reason. Halawi Exchange facilitates transactions as part of a large-
scale trade-based money laundering scheme that involves the purchase of
used cars in the United States for export to West Africa. Additionally,
Halawi Exchange, and its management, ownership, and key employees are
complicit in providing money laundering services for an international
narcotics trafficking and money laundering network that is affiliated
with Hizballah.
A. Past and Current Association With Used Car Trade-Based Money
Laundering Scheme
Halawi Exchange facilitates transactions for a network of
individuals and companies which launder money through the purchase and
sale of used cars in the United States for export to West Africa. In
support of this network, management, ownership, and key employees of
Halawi Exchange coordinate transactions--processed within and outside
of Halawi Exchange--on behalf of Benin-based money launderers and their
associates. A significant portion of the funds are intended for U.S.-
based car dealerships for the purchase of cars which are then shipped
to Benin.
As of late 2012, Halawi Exchange was primarily used by Benin-based
Lebanese car lot owners to wire transfer money to their U.S. suppliers.
The proceeds of car sales were hand-transported in the form of bulk
cash U.S. dollars from Cotonou, Benin to Beirut, Lebanon via air travel
and deposited directly into one of the Halawi Exchange offices, which
allowed bulk cash deposits to be made without requiring documentation
of where the money originated. Halawi Exchange, through its network of
established international exchange houses, initiated wire transfers to
the United States without using the Lebanese banking system in order to
avoid scrutiny associated with Treasury's designations of Hassan Ayash
Exchange, Elissa Exchange, and its LCB 311 Action. The money was wire
transferred indirectly to the United States through countries that
included China, Singapore, and the UAE, which were perceived to receive
less scrutiny by the U.S. Government.
Participants in this network have coordinated the movement of
millions of dollars per month, a significant portion of which has moved
through Halawi Exchange. For example, in early 2012, Halawi Exchange,
its management, its ownership, or key employees were involved in
arranging multiple wire transfers totaling over $4 million on behalf of
this network. Additionally, as of mid-2012, central figures in this
scheme planned to move $224 million worth of vehicle shipping contracts
through this network via a Halawi-owned Benin-based car lot, which
receives vehicle shipments from the United States. Mahmoud Halawi was
heavily involved in the establishment of this car lot, which is run by
Ahmed Tofeily, a Benin-based money launderer, and continues to be
involved in its operations. This car lot was established six months
after the SDNY Complaint. Additionally, Tofeily--a Halawi agent/
employee--owns and operates a car lot in Benin named Auto Deal (AKA Ste
Auto Deal, Societe Auto Deal) which purchases cars in Canada and
exports them through the United States. Tofeily worked closely with
Halawi Exchange and wired all of his money through it. This car lot--
identified as maintaining no brick and mortar structures--has wired
hundreds of thousands of dollars throughout 2012 from Benin to U.S.-
based car dealerships.
[[Page 24599]]
From 2008 to 2011, Halawi Exchange, its management, and employees
sent numerous international wire transfers to U.S.-based used car
companies consistent with the practice of laundering money through the
purchase of cars in the United States for export to West Africa. Ali
Halawi--a partner at Halawi Exchange--is listed by name on many of
these transfers. A large number of these transfers were sent through
accounts at LCB, which has been identified by Treasury as a financial
institution of primary money laundering concern under Section 311 for
its role in facilitating the money laundering activities of Ayman
Joumaa's international narcotics trafficking and money laundering
network. Some of the U.S.-based car dealerships that received funds
transfers from Halawi Exchange were later identified in the SDNY
Complaint as participants in the Joumaa network's money laundering
activities.
Joumaa's network moved illegal drugs from South America to Europe
and the Middle East via West Africa and laundered hundreds of millions
of dollars monthly through accounts held at LCB, as well as through
trade-based money laundering involving consumer goods throughout the
world, including through used car dealerships in the United States.
This criminal scheme involved bulk cash smuggling operations and use of
several Lebanese exchange houses that utilized accounts at LCB
branches, as discussed in the LCB 311 Action.
Halawi Exchange has also worked with other Lebanese exchange
houses, including Rmeiti Exchange, to facilitate money laundering
activities. For example, Halawi Exchange, Rmeiti Exchange, and other
exchange houses sent over $9 million in dozens of round-number, large-
denomination international wire transfers from unknown sources to the
same U.S. car shipping business from 2007 through 2010.
B. Past and Current Connection to Designated Narcotics Kingpins and
Their Associates
SDNTs Ibrahim Chebli and Abbas Hussein Harb regularly coordinated
and executed financial transactions--including bulk cash transfers--
that were processed through the Halawi Exchange. Harb and Chebli were
designated by Treasury in June 2012 pursuant to the Kingpin Act for
collaboration with Joumaa in the movement of millions of dollars of
narcotics-related proceeds. Harb's Columbia- and Venezuela-based
organization has laundered money for the Joumaa network through the
Lebanese financial sector. Additionally, Chebli used his position as
the manager of the Abbassieh branch of Fenicia Bank in Lebanon to
facilitate the movement of money for Joumaa and Harb.\21\
---------------------------------------------------------------------------
\21\ Exhibit 25--Press Release, ``Treasury Targets Major Money
Laundering Network Linked to Drug Trafficker Ayman Joumaa and a Key
Hizballah Supporter in South America,'' 6/27/11, https://www.treasury.gov/press-center/press-releases/Pages/tg1624.aspx
---------------------------------------------------------------------------
C. Past and Current Connection to Another International Narcotics
Trafficking and Money Laundering Network With Ties to Hizballah
Management and key employees at Lebanon-based Halawi Exchange and
members of the Halawi family coordinate, execute, receive, or are
otherwise involved in millions of dollars worth of transactions for
members of another international narcotics trafficking and money
laundering network. For example, high-level management at Lebanon-based
Halawi Exchange and members of the Halawi family were involved in the
movement of over $4 million in late 2012 for this international
narcotics trafficking and money laundering network. Additionally, Fouad
Halawi, acting in his capacity as a senior official at Halawi Holding,
was responsible for the receipt and transfer of funds for this
narcotics trafficking and money laundering network and provided
accounting services for its senior leadership. To avoid detection, the
involved parties scheduled structured payments by splitting larger sums
into smaller, more frequent transactions which they often moved through
numerous high-risk jurisdictions.
This additional international narcotics trafficking and money
laundering network has been involved in extensive international
narcotics trafficking operations. For example, it is known to have
trafficked heroin from Lebanon to the United States and hundred-
kilogram quantities of cocaine from South America to Nigeria for
distribution in Europe and Lebanon. It is also known to have trafficked
cocaine out of Lebanon in multi-ton quantities. The head of this
network has operated an extensive money laundering organization,
including a series of offshore corporate shell companies and underlying
bank accounts, established by intermediaries, to receive and send money
transfers throughout the world. It has arranged the laundering of
profits from large-scale narcotics trafficking operations. Transfers
coordinated by this network have impacted the United States, Canada,
Europe, the Middle East, Asia, Australia, and South America. This
international narcotics trafficking and money laundering network is
affiliated with Hizballah.
Additionally, Halawi Exchange is known to have laundered profits
from drug trafficking and cocaine-related money laundering for a
Hizballah leader and narcotics trafficker. Halawi Exchange has also
been routinely used by other Hizballah associates as a means to
transfer illicit funds.
IV. The Extent to Which This Action Is Sufficient To Guard Against
International Money Laundering and Other Financial Crimes
FinCEN's April 22, 2013, notice of finding that Halawi Exchange is
an institution of primary money laundering concern, along with the
Special Measures simultaneously proposed pursuant to the Finding, will
guard against the international money laundering and other financial
crimes described above directly by restricting the ability of Halawi
Exchange to access the U.S. financial system to process transactions,
and indirectly by public notification to the international financial
community of the risks posed by dealing with Halawi Exchange.
Dated: April 20, 2013.
Jennifer Shasky Calvery,
Director, Financial Crimes Enforcement Network.
[FR Doc. 2013-09785 Filed 4-23-13; 11:15 am]
BILLING CODE 4810-02-P