Hizballah's own sanctions entry has changed, and the two tags added to it say Treasury now treats the group as directed by the Qods Force

The change that matters is on the list, not in the press release.

OFAC rewrote Hizballah's own entry on the Specially Designated Nationals list on Thursday. Before the update the entry carried two programme tags, FTO and SDGT. It now carries four. IRGC and IFSR were added, along with a line recording the group as linked to the Islamic Revolutionary Guard Corps-Qods Force and an organisation type reading transnational terrorist group.

Treasury says the re-designation is made under Executive Order 13224, as amended, for being owned, controlled or directed by, or having acted or purported to act for or on behalf of, the Qods Force. The basis it gives is the coordination by the Qods Force of Hizballah attacks and what the release calls its deep involvement in directing the group's political decision-making.

What did not change

Hizballah has been designated as a foreign terrorist organisation since October 1997 and as a specially designated global terrorist since October 2001, both by the State Department. Thursday's action does not disturb either. The entry also carried a secondary sanctions notice before the update, citing the Hizballah Financial Sanctions Regulations and section 1(b) of Executive Order 13224 as amended by Executive Order 13886, and that text appears word for word in the version published after it. So the addition is a second basis for the designation rather than a new exposure for foreign banks.

The ten couriers

Treasury says the network moved cash for Hizballah on commercial airline flights between Lebanon, Turkey, the United Arab Emirates and Iran, and describes the sums as running up to hundreds of millions of dollars across those jurisdictions. It names Yunus Alper Yilmaz, a Turkish businessman, as the manager, and says he used exchange houses in Turkey as fronts and supplied front companies and bank accounts for transfers connected with the Qods Force. Halil Ibrahim Kacmaz and Onder Dede are described as collecting the cash from those exchange houses. Vasfi Akyuz is described as coordinating logistics for the couriers and carrying cash himself.

Six more are listed as couriers who carried cash covertly on flights to Lebanon: Mehmet Akyuz, Mehmet Acur, Feyyad Karasalih, Masoud Mousafar, Gulay Kaya Savci and Emrah Ayaz.

Three of the ten, Yilmaz, Kacmaz and Dede, are designated for supporting the Qods Force. The other seven are designated for supporting Hizballah. A designation is not a criminal charge, and no court has ruled on any of it.

What the entries themselves add

Nine of the ten record Turkish nationality. The tenth, Mousafar, is recorded as Iranian, at an address in Turkey, and the only passport on his entry expired in August 2020. Most of the Turkish entries carry a street address in Istanbul or Adana and a national identity number, which is the level of detail a screening system can actually use.

The release also places the network in a longer story. It says the group was once associated with Behnam Shahriyari, a Qods Force finance official it describes as now deceased.