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Sanctions Compliance Regulations in Lebanon: A Crucial Guide for Businesses

The United States government has implemented a comprehensive sanctions program targeting Lebanon, aimed at undermining the country’s sovereignty and democratic institutions. The Office of Foreign Assets Control (OFAC) is responsible for enforcing these regulations, which apply to U.S. persons and entities as well as those doing business with or in the United States.

Understanding the Authorities

Executive Order 13441, issued on August 1, 2007, provides the legal framework for sanctions against Lebanon. The order prohibits transactions involving individuals and entities deemed to be undermining the country’s democratic processes or institutions. OFAC has also issued the Lebanon Sanctions Regulations (31 C.F.R. Part 549), which outlines the specific requirements for complying with these regulations.

Blocked Persons

The Treasury Department maintains a list of Specially Designated Nationals (SDNs) and Blocked Persons, which includes individuals and entities subject to sanctions. This list is regularly updated, and businesses must ensure they do not engage in transactions involving blocked persons or entities owned 50% or more by them.

Key Points to Note

  • The list of SDNs and Blocked Persons is regularly updated.
  • Businesses must verify the identity of customers and business partners.
  • Conduct regular reviews of transactions involving blocked persons or entities.

Authorized Transactions

OFAC may issue general licenses allowing certain activities and transactions that would otherwise be prohibited. These licenses are published on OFAC’s website and provide specific guidance for complying with the regulations. Businesses can also request a specific license from OFAC, which must be submitted in writing using one of three methods: online, fax, or mail.

Penalties for Non-Compliance

Failure to comply with sanctions regulations can result in significant penalties, including civil monetary fines of up to $250,000 or twice the amount of the underlying transaction. In addition, individuals and entities may face criminal charges, including fines of up to $1 million, imprisonment for up to 20 years, or both.

What Businesses Must Do

To ensure compliance with sanctions regulations in Lebanon, businesses must:

  • Verify the identity of customers and business partners
  • Conduct regular reviews of transactions involving blocked persons or entities
  • Obtain specific licenses from OFAC when necessary
  • Implement effective internal controls and monitoring procedures
  • Report any suspicious activities to OFAC

Contact Information

For additional information about sanctions relating to Lebanon or other countries, please contact:

Office of Foreign Assets Control (OFAC) U.S. Department of the Treasury 1500 Pennsylvania Avenue, N.W. Washington, D.C. 20220 www.treasury.gov/ofac 202/622-2490