On September 17, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions pursuant to Executive Order 13224 against members of Lebanon- and Kuwait-based financial conduits that fund Hizballah. In addition, OFAC designated members of an international network of financial facilitators and front companies connected to Hizballah and Iran’s Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF). Together, these networks allegedly “laundered tens of millions of dollars through regional financial systems and conducted currency exchanges and trades” for the benefit of both entities. According to OFAC, Hizballah, supported by the IRGC-QF, utilized the revenues from these networks to fund terrorism, and condoned instability throughout the region. As a result, all property and interests in property belonging to the designated persons subject to U.S. jurisdiction are blocked, and any “entities that are owned, directly or indirectly, 50 percent or more by them, individually, or with other blocked persons, that are in the United States or in control of a U.S. person must be blocked.” U.S. persons are “generally prohibited from engaging in transactions” with the designated members. OFAC further warned that the agency “can prohibit or impose strict conditions on the opening or maintaining in the United States of a correspondent account or a payable-through account by a foreign financial institution that either knowingly conducted or facilitated any significant transaction on behalf of a Specially Designated Global Terrorist or, among other things, knowingly facilitates a significant transaction for Hizballah or certain persons designated for their connection to Hizballah.”