Al‑Qard Al‑Hassan (AQAH) is a Lebanon‑licensed NGO established in the 1980s that functions like an informal bank within Hezbollah’s Shiite constituencies—offering interest‑free loans, pawnbroking against jewelry, and other cash services through dozens of branches. U.S. and other authorities say AQAH is controlled by Hezbollah, has been used to move funds via shadow accounts and shell companies (including gold‑trading firms) to evade sanctions, and expanded role during Lebanon’s financial crisis when formal banking access tightened.
Designation under Executive Order 13224 (as applied here) generally means the U.S. blocks all identified property and interests in the U.S. or controlled by U.S. persons, adds the individuals/entities to sanctions lists (e.g., OFAC’s SDN/blocked lists), and prohibits U.S. persons from dealing with them; violations can trigger civil and criminal penalties and may expose foreign banks or companies to secondary U.S. sanctions.
National Security Presidential Memorandum 2 (NSPM‑2), issued Feb. 4, 2025, articulates the Biden (or later) Administration’s ‘‘maximum pressure’’ whole‑of‑government policy toward Iran and its proxies—directing intensified use of sanctions, financial disruption, and coordinated actions across agencies to cut Tehran’s covert funding to groups like Hezbollah. It formalizes tougher, cross‑agency measures to disrupt Iran’s networks rather than a narrow diplomatic approach.
Sanctions targeting AQAH and its facilitators can reduce liquidity and services provided by those informal networks (loans, gold exchanges, pawnbroking and cash conversion), potentially limiting access to cash for ordinary Lebanese who depend on them—while U.S. officials argue the measures aim to disrupt militant financing not ordinary users. In practice, sanctions can cause increased banking restrictions, branch closures or reduced services and raise costs for remittances and small credit for vulnerable households.
Primary enforcement and implementation are led by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC); the State Department issues terrorism designations under E.O. 13224; the Department of Justice enforces criminal violations. The official lists and details of designated persons are published by OFAC (SDN/Blocked Lists and Recent Actions) and by the State Department’s designations pages.
U.S. investigators typically use financial intelligence (bank records, transaction flows), open‑source and classified intelligence, commercial shipping and customs data, corporate registry records, and multilaterally shared information to trace procurement, gold and commodity trades, shell companies and shipping routes; public and agency statements on specific cases cite this mix of financial forensics and partner‑country investigations linking Iran to Hezbollah financing.