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OFAC Shakes $100K Hezbollah Financing Network

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Treasury’s Office of Foreign Assets Control (OFAC) has taken decisive steps to dismantle the complex web of Hezbollah financial facilitators, cutting off critical cash flows that sustain terrorist operations. On May 15, 2025, OFAC designated two senior Hezbollah officials and two key money channels under Executive Order 13224. This move ratchets up economic pressure on Tehran’s proxies by targeting overseas donation pipelines, a lifeline for Hizballah’s budget.

Hezbollah depends heavily on contributions from supporters worldwide. Much of this funding travels through covert channels originating in Iran and Lebanon before reaching operatives who allocate resources to the group’s military, political, and social arms. Mu’in Daqiq Al-‘Amili, a senior Hezbollah representative based in Qom, Iran, coordinated the transfer of tens of thousands of U.S. dollars to Lebanese finance chiefs directly linked to Secretary General Hassan Nasrallah’s office. During late 2023 and early 2024, Al-‘Amili oversaw at least $50,000 in cash deliveries from Iran to Lebanon, funds that likely supported operations in Gaza and elsewhere.

Fadi Nehme, an accountant and business partner of Ibrahim Ali Daher, OFAC-designated in May 2021 for steering the Hezbollah Central Finance Unit, The Long-Standing Connection Between Drug Cartels and Terrorist Organizations facilitated transactions through his stake in Auditors for Accounting and Auditing. This firm, also designated in December 2022, processed and laundered donations destined for Hezbollah. Meanwhile, Hasan Abdallah Ni’mah managed millions of dollars in transfers for Hezbollah-aligned entities across Africa, channeling substantial sums to groups like the Islamic Movement of Nigeria.

“Today’s action underscores Hezbollah’s extensive global reach through its network of terrorist donors and supporters, particularly in Tehran,” said Deputy Secretary of the Treasury Michael Faulkender. “As part of our ongoing efforts to address Iran’s support for terrorism, Treasury will continue to intensify economic pressure on the key individuals in the Iranian regime and its proxies who enable these deadly activities.”

By severing these financial arteries, OFAC aims to starve Hezbollah of the resources needed for recruitment, weapons procurement, and regional influence. This latest campaign builds on a series of sanctions targeting oil sales networks and commercial fronts used by the group to mask its illicit revenue streams.

Legal Framework and U.S. Authorities

OFAC’s designations rest on the authority of Executive Order 13224, originally issued post-9/11 to freeze assets of terrorists and their supporters. Amended multiple times, E.O. 13224 empowers the Treasury Secretary to block property and interests of designated individuals and entities. Hezbollah’s September 2001 designation as a Specially Designated Global Terrorist by the Department of State under this order laid the groundwork for subsequent punitive actions.

National Security Presidential Memorandum 2 (NSPM-2), signed in December 2018, amplifies the “maximum pressure” strategy on Iran and its proxies, including Hezbollah. NSPM-2 calls for coordinated sanctions to disrupt terrorist financing, ballistic missile development, and other malign activities. Under this mandate, OFAC has targeted Hezbollah’s oil network, procurement channels, and now, its sophisticated money transfer mechanisms.

Regulatory compliance falls under 31 C.F.R. Part 594 (the “Global Terrorist Sanctions Regulations”), where U.S. persons and financial institutions must freeze assets of SDGTs. Violations can incur civil penalties under the International Emergency Economic Powers Act (50 U.S.C. § 1705) or criminal fines up to $1,000,000 and 20 years’ imprisonment. Secondary sanctions threaten non-U.S. banks with loss of U.S. correspondent banking privileges, deterring global financial actors from processing transactions linked to designated Hezbollah facilitators.

Further constraints arise from export control laws. Transactions involving entities on the Specially Designated Nationals and Blocked Persons List trigger restrictions under the Export Administration Regulations (15 C.F.R. § 744.8), administered by the Bureau of Industry and Security. These provisions bar exports, reexports, or transfers of dual-use items to SDGT-linked individuals without prior Commerce Department licensing.

Profiles of the Sanctioned Individuals

Mu’in Daqiq Al-‘Amili
Based in Qom, Iran, Al-‘Amili has coordinated Hezbollah’s foreign donations since at least 2001. His deep ties to the Hezbollah Foreign Relations Department enabled him to channel cash from Iran to Lebanon. Notably, he facilitated at least $50,000 in late 2023, likely earmarked for Gaza operations. His longstanding operational relationship with senior financial operatives makes him a linchpin in the group’s fundraising network.

Jihad Alami (Alami)
Operating in Lebanon, Alami received and distributed funds procured by Al-‘Amili. As the financial conduit for Secretary General Nasrallah’s office, Alami managed large cash pools, steering them toward military, humanitarian, and propaganda activities. His role exemplifies Hezbollah reliance on trusted intermediaries to move cash outside formal banking channels.

Fadi Nehme
An accountant and part-owner of Auditors for Accounting and Auditing, Nehme has laundered donations through legitimate-looking accounting services. His partnership with Ibrahim Ali Daher positioned him at the heart of the Hezbollah Central Finance Unit. Nehme’s work underscores how professional services can be weaponized to obscure funding flows in terrorist financing schemes.

Hasan Abdallah Ni’mah
Ni’mah’s remit spans Africa, where he funneled millions to groups sympathetic to Hezbollah ideology. His coordination of hundreds of thousands of dollars to Nigeria’s Islamic Movement illustrates the geographic breadth of Hezbollah’s outreach. Ni’mah’s network highlights the intersection of ideology and opportunism, recruiting regional actors into the group’s financial orbit.

All four individuals were designated under E.O. 13224 for materially assisting, sponsoring, or acting on behalf of Hezbollah. Their collective removal from global financial systems severely undermines Hezbollah’s ability to fund operations and sustain loyalty among overseas supporters.

Impact of Sanctions and Enforcement Mechanisms

OFAC’s blocking of property and interests in designated Hezbollah financial facilitators triggers immediate consequences. U.S. persons and entities must report blocked assets to OFAC and cease all dealings with the SDGTs. Banks face strict liability for sanctions breaches, with civil penalties starting at $50,000 per violation and criminal fines for willful conduct. Compliance regimes now include enhanced due diligence on clients connected to the Levant and secondary sanctions risk assessments.

Non-U.S. financial institutions are compelled to choose between U.S. market access and maintaining relationships with Hezbollah-linked clients. Secondary sanctions can blacklist foreign banks from U.S. dollar clearing, a crippling outcome. Export controls further limit Hizballah’s procurement of sensitive goods, from communication tech to equipment with dual military applications.

Enforcement actions often involve collaborative investigations by law enforcement and regulatory agencies. OFAC’s Economic Sanctions Enforcement Guidelines emphasize voluntary self-disclosures and robust compliance as mitigating factors. Yet, the agency retains discretion to impose heavy penalties, as seen in recent multi-million-dollar settlements with global banks over Iran-related violations.

By severing financing conduits, the U.S. government hampers Hezbollah’s capacity to recruit fighters, obtain arms, and project power across the Middle East and Africa. The ripple effects extend to charitable fronts used for façade humanitarian aid, forcing them to curtail operations or face designation themselves.

Conclusion

OFAC’s latest designations against Hezbollah financial facilitators mark a significant escalation in the campaign to choke off terrorist financing. By targeting core money brokers—Al-‘Amili, Alami, Nehme, and Ni’mah—the Treasury disrupts key nodes in a transnational network stretching from Iran to Lebanon and into Africa. Coupled with robust enforcement mechanisms under E.O. 13224, NSPM-2, and export control regulations, this action delivers a powerful blow to Hizballah’s fiscal infrastructure.

Sustained economic pressure remains the cornerstone of U.S. strategy against Iran and its proxies. As Hezbollah seeks to rebuild post-conflict resources, the Treasury’s punitive measures send a clear message: global financial engagement with terrorist affiliates carries unacceptable risk. Financial institutions and other actors must adopt rigorous compliance protocols to avoid facilitating illicit transfers. Continued vigilance and coordinated sanctions implementation will be essential for diminishing Hezbollah’s ability to fund malign operations and safeguarding international peace and security.