Lebanese Canadian Bank - Revision history

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	Authorities continued to investigate financial relationships surrounding the former bank. In 2013, Treasury alleged that Rmeiti and Halawi exchange houses had taken over related laundering activity after the LCB action. It described both used-car transactions and consumer-goods trading. The businesses disputed the accusations. Their cases concerned separate institutions that authorities believed had continued parts of the network’s work after the bank’s closure.<ref name="r7" /><ref name="r8" /><ref name="r4" /><ref name="r6" /><ref name="r40" />		Authorities continued to investigate financial relationships surrounding the former bank. In 2013, Treasury alleged that Rmeiti and Halawi exchange houses had taken over related laundering activity after the LCB action. It described both used-car transactions and consumer-goods trading. The businesses disputed the accusations. Their cases concerned separate institutions that authorities believed had continued parts of the network’s work after the bank’s closure.<ref name="r7" /><ref name="r8" /><ref name="r4" /><ref name="r6" /><ref name="r40" />

	Treasury attributed at least $25 million in payments to U.S. car dealers and exporters to Rmeiti between 2008 and March 2011. [[Financial Crimes Enforcement Network\|FinCEN]]’s finding also described payments involving Kharroubi and Ellissa-related activity. The Halawi finding discussed transfers to U.S. used-car companies during ~~2008–2011~~, including through LCB accounts. These findings followed the exchange businesses and their counterparties across the period of the bank’s intervention.<ref name="r40" /><ref name="r8" /><ref name="r7" />		Treasury attributed at least $25 million in payments to U.S. car dealers and exporters to Rmeiti between 2008 and March 2011. [[Financial Crimes Enforcement Network\|FinCEN]]’s finding also described payments involving Kharroubi and Ellissa-related activity. The Halawi finding discussed transfers to U.S. used-car companies during 2008 - 2011, including through LCB accounts. These findings followed the exchange businesses and their counterparties across the period of the bank’s intervention.<ref name="r40" /><ref name="r8" /><ref name="r7" />

	Later civil litigation concerned other Lebanese banks. FDD’s discussion of the Bartlett complaint described allegations that accounts, including Phenicia Shipping’s, migrated from LCB to Fransabank. Those allegations concerned the subsequent movement of financial relationships and were separate from the terms on which LCB settled its own civil case.<ref name="r41" />		Later civil litigation concerned other Lebanese banks. FDD’s discussion of the Bartlett complaint described allegations that accounts, including Phenicia Shipping’s, migrated from LCB to Fransabank. Those allegations concerned the subsequent movement of financial relationships and were separate from the terms on which LCB settled its own civil case.<ref name="r41" />

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	Treasury’s February 2011 announcement stated that [[Hezbollah]] derived financial support from the criminal activities of Joumaa’s network. The later civil case described more specific forms of alleged participation: financing some vehicle purchases, transporting cash, protecting shipments and facilitating transfers from West Africa to Lebanon. Prosecutors alleged that Joumaa’s organization paid fees to Hezbollah operatives for courier and laundering services. These claims concerned benefit and facilitation within a larger financial stream; the vehicle-transfer total was not presented as a quantified payment to Hezbollah. Those allegations also did not establish Hezbollah's ownership of LCB.<ref name="r1" /><ref name="r3" /><ref name="r11" /><ref name="r2" /><ref name="r28" />		Treasury’s February 2011 announcement stated that [[Hezbollah]] derived financial support from the criminal activities of Joumaa’s network. The later civil case described more specific forms of alleged participation: financing some vehicle purchases, transporting cash, protecting shipments and facilitating transfers from West Africa to Lebanon. Prosecutors alleged that Joumaa’s organization paid fees to Hezbollah operatives for courier and laundering services. These claims concerned benefit and facilitation within a larger financial stream; the vehicle-transfer total was not presented as a quantified payment to Hezbollah. Those allegations also did not establish Hezbollah's ownership of LCB.<ref name="r1" /><ref name="r3" /><ref name="r11" /><ref name="r2" /><ref name="r28" />

	Other allegations concerned relationships at the bank itself. Treasury identified Hezbollah’s Tehran-based envoy [[Abdallah Safieddine]] as involved in Iranian officials’ access to LCB and key managers. Its 2018 announcement concerning [[Mohammad Ibrahim Bazzi\|Mohammad Bazzi]] recalled that allegation and described Safieddine and Bazzi working on banking access between Iran and Lebanon in ~~2009–2010~~. The later announcement broadened the account of named intermediaries without making every transaction associated with them an LCB transaction.<ref name="r2" /><ref name="r29" />		Other allegations concerned relationships at the bank itself. Treasury identified Hezbollah’s Tehran-based envoy [[Abdallah Safieddine]] as involved in Iranian officials’ access to LCB and key managers. Its 2018 announcement concerning [[Mohammad Ibrahim Bazzi\|Mohammad Bazzi]] recalled that allegation and described Safieddine and Bazzi working on banking access between Iran and Lebanon in 2009 - 2010. The later announcement broadened the account of named intermediaries without making every transaction associated with them an LCB transaction.<ref name="r2" /><ref name="r29" />

	The amended complaint also alleged banking relationships with Yousser Company for Finance and Investment and Bayt al-Mal, managed through LCB’s Airport Road branch in Beirut. It described loans to Yousser guaranteed by a company director identified as Hussain Shami. A Congressional Research Service background report published before the LCB action listed Yousser and Bayt al-Mal among entities designated by the United States as Hezbollah financial conduits. The pre-existing designations and the later allegations about LCB accounts were distinct parts of the chronology.<ref name="r11" /><ref name="r30" />		The amended complaint also alleged banking relationships with Yousser Company for Finance and Investment and Bayt al-Mal, managed through LCB’s Airport Road branch in Beirut. It described loans to Yousser guaranteed by a company director identified as Hussain Shami. A Congressional Research Service background report published before the LCB action listed Yousser and Bayt al-Mal among entities designated by the United States as Hezbollah financial conduits. The pre-existing designations and the later allegations about LCB accounts were distinct parts of the chronology.<ref name="r11" /><ref name="r30" />

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	By the period preceding the U.S. intervention, LCB was described as Lebanon’s eighth-largest bank. It employed more than 600 people and held assets exceeding $5 billion in 2009. Its international correspondent relationships allowed it to arrange payments through other banks, including institutions in the United States. These were ordinary commercial banking capabilities; the dispute concerned how particular customers used them and what bank managers knew about that use. The bank's assets were not a measure of criminal proceeds, and its international subsidiaries did not establish participation by every subsidiary or customer.<ref name="r11" /><ref name="r1" /><ref name="r5" /><ref name="r9" />		By the period preceding the U.S. intervention, LCB was described as Lebanon’s eighth-largest bank. It employed more than 600 people and held assets exceeding $5 billion in 2009. Its international correspondent relationships allowed it to arrange payments through other banks, including institutions in the United States. These were ordinary commercial banking capabilities; the dispute concerned how particular customers used them and what bank managers knew about that use. The bank's assets were not a measure of criminal proceeds, and its international subsidiaries did not establish participation by every subsidiary or customer.<ref name="r11" /><ref name="r1" /><ref name="r5" /><ref name="r9" />

	Its subsidiaries included businesses dealing in investment, finance, property, insurance brokerage and securities. LCB also owned 51 percent of Prime Bank Limited in Gambia. FinCEN described the remaining shares as held by local and Lebanese partners and said LCB apparently served as Prime Bank’s sole correspondent bank. A later ~~KAS–Counter~~ Extremism Project study examined this relationship within its account of financial connections between Lebanon and West Africa.<ref name="r9" /><ref name="r12" />		Its subsidiaries included businesses dealing in investment, finance, property, insurance brokerage and securities. LCB also owned 51 percent of Prime Bank Limited in Gambia. FinCEN described the remaining shares as held by local and Lebanese partners and said LCB apparently served as Prime Bank’s sole correspondent bank. A later KAS - Counter Extremism Project study examined this relationship within its account of financial connections between Lebanon and West Africa.<ref name="r9" /><ref name="r12" />

	== The 2011 regulatory action ==		== The 2011 regulatory action ==

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	[[File:Lebanese Canadian Bank.~~webp~~\|thumb\|upright=1.25\|alt=~~Editorial illustration:~~ Lebanese Canadian Bank~~\|Illustration of Ayman Joumaa based on a Treasury archival photograph alongside generic banking and vehicle-transfer imagery; not a documentary photograph or depiction of a specific transaction~~.]]		[[File:Lebanese Canadian Bank.jpg\|thumb\|upright=1.25\|alt=This is a photograph from the memorial service of Jihad Mughniyah held at the representative office of the Lebanese Hezbollah in Tehran, Iran.\|Illustration for the entry Lebanese Canadian Bank. Photo: Mehdi Bolourian ([https://commons.wikimedia.org/wiki/File:Memorial_service_of_Jihad_Mughniyah_in_Hezbollah%27s_Tehran_office_(14).jpg Wikimedia Commons]), [https://creativecommons.org/licenses/by/4.0 CC BY 4.0].]]

	'''Lebanese Canadian Bank''' (LCB) was a Beirut-based bank whose international payment services became the subject of U.S. money-laundering investigations. Established in 1960, it developed a network of branches in Lebanon and banking relationships abroad. In February 2011, the U.S. [[Financial Crimes Enforcement Network]] (FinCEN) identified it as a financial institution of primary money-laundering concern, alleging that its accounts helped an international network move narcotics proceeds. The bank denied wrongdoing and management involvement in the alleged activities.<ref name="r1" /><ref name="r2" /><ref name="r3" /><ref name="r4" /><ref name="r5" /><ref name="r6" /><ref name="r7" /><ref name="r8" /><ref name="r9" /><ref name="r10" />		'''Lebanese Canadian Bank''' (LCB) was a Beirut-based bank whose international payment services became the subject of U.S. money-laundering investigations. Established in 1960, it developed a network of branches in Lebanon and banking relationships abroad. In February 2011, the U.S. [[Financial Crimes Enforcement Network]] (FinCEN) identified it as a financial institution of primary money-laundering concern, alleging that its accounts helped an international network move narcotics proceeds. The bank denied wrongdoing and management involvement in the alleged activities.<ref name="r1" /><ref name="r2" /><ref name="r3" /><ref name="r4" /><ref name="r5" /><ref name="r6" /><ref name="r7" /><ref name="r8" /><ref name="r9" /><ref name="r10" />

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	Authorities continued to investigate financial relationships surrounding the former bank. In 2013, Treasury alleged that Rmeiti and Halawi exchange houses had taken over related laundering activity after the LCB action. It described both used-car transactions and consumer-goods trading. The businesses disputed the accusations. Their cases concerned separate institutions that authorities believed had continued parts of the network’s work after the bank’s closure.<ref name="r7" /><ref name="r8" /><ref name="r4" /><ref name="r6" /><ref name="r40" />		Authorities continued to investigate financial relationships surrounding the former bank. In 2013, Treasury alleged that Rmeiti and Halawi exchange houses had taken over related laundering activity after the LCB action. It described both used-car transactions and consumer-goods trading. The businesses disputed the accusations. Their cases concerned separate institutions that authorities believed had continued parts of the network’s work after the bank’s closure.<ref name="r7" /><ref name="r8" /><ref name="r4" /><ref name="r6" /><ref name="r40" />

	Treasury attributed at least $25 million in payments to U.S. car dealers and exporters to Rmeiti between 2008 and March 2011. ~~FinCEN’s~~ finding also described payments involving Kharroubi and Ellissa-related activity. The Halawi finding discussed transfers to U.S. used-car companies during 2008–2011, including through LCB accounts. These findings followed the exchange businesses and their counterparties across the period of the bank’s intervention.<ref name="r40" /><ref name="r8" /><ref name="r7" />		Treasury attributed at least $25 million in payments to U.S. car dealers and exporters to Rmeiti between 2008 and March 2011. [[Financial Crimes Enforcement Network\|FinCEN]]’s finding also described payments involving Kharroubi and Ellissa-related activity. The Halawi finding discussed transfers to U.S. used-car companies during 2008–2011, including through LCB accounts. These findings followed the exchange businesses and their counterparties across the period of the bank’s intervention.<ref name="r40" /><ref name="r8" /><ref name="r7" />

	Later civil litigation concerned other Lebanese banks. FDD’s discussion of the Bartlett complaint described allegations that accounts, including Phenicia Shipping’s, migrated from LCB to Fransabank. Those allegations concerned the subsequent movement of financial relationships and were separate from the terms on which LCB settled its own civil case.<ref name="r41" />		Later civil litigation concerned other Lebanese banks. FDD’s discussion of the Bartlett complaint described allegations that accounts, including Phenicia Shipping’s, migrated from LCB to Fransabank. Those allegations concerned the subsequent movement of financial relationships and were separate from the terms on which LCB settled its own civil case.<ref name="r41" />

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	[[Financial Crimes Enforcement Network\|FinCEN]] withdrew the proposed restriction in October 2015 after the liquidation of LCB’s assets and revocation of its banking license meant it no longer existed as a foreign financial institution. The withdrawal concerned the proposed restriction on U.S. correspondent and payable-through accounts. It did not convert the earlier proposal into a rule that had previously taken effect.<ref name="r1" /><ref name="r15" /><ref name="r2" /><ref name="r6" />		[[Financial Crimes Enforcement Network\|FinCEN]] withdrew the proposed restriction in October 2015 after the liquidation of LCB’s assets and revocation of its banking license meant it no longer existed as a foreign financial institution. The withdrawal concerned the proposed restriction on U.S. correspondent and payable-through accounts. It did not convert the earlier proposal into a rule that had previously taken effect.<ref name="r1" /><ref name="r15" /><ref name="r2" /><ref name="r6" />

	FinCEN expressly stated that the withdrawal did not acknowledge remedial action by LCB. Its stated reason was the disappearance of the institution to which the proposed measure would have applied. This regulatory endpoint was separate from the 2013 ~~civil~~ forfeiture and from the bank’s retained denial of wrongdoing.<ref name="r1" /><ref name="r15" /><ref name="r6" /><ref name="r4" /><ref name="r2" /><ref name="r3" /><ref name="r5" /><ref name="r7" /><ref name="r8" />		FinCEN expressly stated that the withdrawal did not acknowledge remedial action by LCB. Its stated reason was the disappearance of the institution to which the proposed measure would have applied. This regulatory endpoint was separate from the 2013 [[Civil forfeiture]] and from the bank’s retained denial of wrongdoing.<ref name="r1" /><ref name="r15" /><ref name="r6" /><ref name="r4" /><ref name="r2" /><ref name="r3" /><ref name="r5" /><ref name="r7" /><ref name="r8" />

	== Subsequent investigations ==		== Subsequent investigations ==

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	== Withdrawal of the proposed rule ==		== Withdrawal of the proposed rule ==

	FinCEN withdrew the proposed restriction in October 2015 after the liquidation of LCB’s assets and revocation of its banking license meant it no longer existed as a foreign financial institution. The withdrawal concerned the proposed restriction on U.S. correspondent and payable-through accounts. It did not convert the earlier proposal into a rule that had previously taken effect.<ref name="r1" /><ref name="r15" /><ref name="r2" /><ref name="r6" />		[[Financial Crimes Enforcement Network\|FinCEN]] withdrew the proposed restriction in October 2015 after the liquidation of LCB’s assets and revocation of its banking license meant it no longer existed as a foreign financial institution. The withdrawal concerned the proposed restriction on U.S. correspondent and payable-through accounts. It did not convert the earlier proposal into a rule that had previously taken effect.<ref name="r1" /><ref name="r15" /><ref name="r2" /><ref name="r6" />

	FinCEN expressly stated that the withdrawal did not acknowledge remedial action by LCB. Its stated reason was the disappearance of the institution to which the proposed measure would have applied. This regulatory endpoint was separate from the 2013 civil forfeiture and from the bank’s retained denial of wrongdoing.<ref name="r1" /><ref name="r15" /><ref name="r6" /><ref name="r4" /><ref name="r2" /><ref name="r3" /><ref name="r5" /><ref name="r7" /><ref name="r8" />		FinCEN expressly stated that the withdrawal did not acknowledge remedial action by LCB. Its stated reason was the disappearance of the institution to which the proposed measure would have applied. This regulatory endpoint was separate from the 2013 civil forfeiture and from the bank’s retained denial of wrongdoing.<ref name="r1" /><ref name="r15" /><ref name="r6" /><ref name="r4" /><ref name="r2" /><ref name="r3" /><ref name="r5" /><ref name="r7" /><ref name="r8" />

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	Treasury’s February 2011 announcement stated that [[Hezbollah]] derived financial support from the criminal activities of Joumaa’s network. The later civil case described more specific forms of alleged participation: financing some vehicle purchases, transporting cash, protecting shipments and facilitating transfers from West Africa to Lebanon. Prosecutors alleged that Joumaa’s organization paid fees to Hezbollah operatives for courier and laundering services. These claims concerned benefit and facilitation within a larger financial stream; the vehicle-transfer total was not presented as a quantified payment to Hezbollah. Those allegations also did not establish Hezbollah's ownership of LCB.<ref name="r1" /><ref name="r3" /><ref name="r11" /><ref name="r2" /><ref name="r28" />		Treasury’s February 2011 announcement stated that [[Hezbollah]] derived financial support from the criminal activities of Joumaa’s network. The later civil case described more specific forms of alleged participation: financing some vehicle purchases, transporting cash, protecting shipments and facilitating transfers from West Africa to Lebanon. Prosecutors alleged that Joumaa’s organization paid fees to Hezbollah operatives for courier and laundering services. These claims concerned benefit and facilitation within a larger financial stream; the vehicle-transfer total was not presented as a quantified payment to Hezbollah. Those allegations also did not establish Hezbollah's ownership of LCB.<ref name="r1" /><ref name="r3" /><ref name="r11" /><ref name="r2" /><ref name="r28" />

	Other allegations concerned relationships at the bank itself. Treasury identified Hezbollah’s Tehran-based envoy Abdallah Safieddine as involved in Iranian officials’ access to LCB and key managers. Its 2018 announcement concerning [[Mohammad Ibrahim Bazzi\|Mohammad Bazzi]] recalled that allegation and described Safieddine and Bazzi working on banking access between Iran and Lebanon in 2009–2010. The later announcement broadened the account of named intermediaries without making every transaction associated with them an LCB transaction.<ref name="r2" /><ref name="r29" />		Other allegations concerned relationships at the bank itself. Treasury identified Hezbollah’s Tehran-based envoy [[Abdallah Safieddine]] as involved in Iranian officials’ access to LCB and key managers. Its 2018 announcement concerning [[Mohammad Ibrahim Bazzi\|Mohammad Bazzi]] recalled that allegation and described Safieddine and Bazzi working on banking access between Iran and Lebanon in 2009–2010. The later announcement broadened the account of named intermediaries without making every transaction associated with them an LCB transaction.<ref name="r2" /><ref name="r29" />

	The amended complaint also alleged banking relationships with Yousser Company for Finance and Investment and Bayt al-Mal, managed through LCB’s Airport Road branch in Beirut. It described loans to Yousser guaranteed by a company director identified as Hussain Shami. A Congressional Research Service background report published before the LCB action listed Yousser and Bayt al-Mal among entities designated by the United States as Hezbollah financial conduits. The pre-existing designations and the later allegations about LCB accounts were distinct parts of the chronology.<ref name="r11" /><ref name="r30" />		The amended complaint also alleged banking relationships with Yousser Company for Finance and Investment and Bayt al-Mal, managed through LCB’s Airport Road branch in Beirut. It described loans to Yousser guaranteed by a company director identified as Hussain Shami. A Congressional Research Service background report published before the LCB action listed Yousser and Bayt al-Mal among entities designated by the United States as Hezbollah financial conduits. The pre-existing designations and the later allegations about LCB accounts were distinct parts of the chronology.<ref name="r11" /><ref name="r30" />

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	[[Financial Crimes Enforcement Network\|FinCEN]] also described a route involving consumer goods from Asia. In its account, funds passed through LCB’s U.S. correspondent accounts to suppliers whose goods were shipped to Latin America and sold. Proceeds were then settled through a [[Black Market Peso Exchange]] arrangement, linking commercial purchases with the conversion and return of drug proceeds. The Asian-goods route and the vehicle route served different markets but allegedly used the bank’s international payment services for a similar purpose. The finding left some participants unnamed; those descriptions do not identify them with people in later cases.<ref name="r1" /><ref name="r9" />		[[Financial Crimes Enforcement Network\|FinCEN]] also described a route involving consumer goods from Asia. In its account, funds passed through LCB’s U.S. correspondent accounts to suppliers whose goods were shipped to Latin America and sold. Proceeds were then settled through a [[Black Market Peso Exchange]] arrangement, linking commercial purchases with the conversion and return of drug proceeds. The Asian-goods route and the vehicle route served different markets but allegedly used the bank’s international payment services for a similar purpose. The finding left some participants unnamed; those descriptions do not identify them with people in later cases.<ref name="r1" /><ref name="r9" />

	Later litigation supplied additional accounts of exchange-house transactions. A Foundation for Defense of Democracies (FDD) study reproduced a claim from the Bartlett lawsuit involving a $20,000 cash deposit by Abdul Latif Fawaz at New Line Exchange in 2008. According to that complaint, New Line then instructed LCB to debit its dollar account and transfer funds to an individual’s account at SGBL. This was a separate alleged transaction illustrating an exchange-to-bank payment sequence, rather than an identified Joumaa transfer.<ref name="r27" />		Later litigation supplied additional accounts of exchange-house transactions. A Foundation for Defense of Democracies (FDD) study reproduced a claim from the Bartlett lawsuit involving a $20,000 cash deposit by Abdul Latif Fawaz at [[New Line Exchange Trust\|New Line Exchange]] in 2008. According to that complaint, New Line then instructed LCB to debit its dollar account and transfer funds to an individual’s account at SGBL. This was a separate alleged transaction illustrating an exchange-to-bank payment sequence, rather than an identified Joumaa transfer.<ref name="r27" />

	== Alleged Hezbollah relationships ==		== Alleged Hezbollah relationships ==

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	== Consumer goods and other payment routes ==		== Consumer goods and other payment routes ==

	FinCEN also described a route involving consumer goods from Asia. In its account, funds passed through LCB’s U.S. correspondent accounts to suppliers whose goods were shipped to Latin America and sold. Proceeds were then settled through a [[Black Market Peso Exchange]] arrangement, linking commercial purchases with the conversion and return of drug proceeds. The Asian-goods route and the vehicle route served different markets but allegedly used the bank’s international payment services for a similar purpose. The finding left some participants unnamed; those descriptions do not identify them with people in later cases.<ref name="r1" /><ref name="r9" />		[[Financial Crimes Enforcement Network\|FinCEN]] also described a route involving consumer goods from Asia. In its account, funds passed through LCB’s U.S. correspondent accounts to suppliers whose goods were shipped to Latin America and sold. Proceeds were then settled through a [[Black Market Peso Exchange]] arrangement, linking commercial purchases with the conversion and return of drug proceeds. The Asian-goods route and the vehicle route served different markets but allegedly used the bank’s international payment services for a similar purpose. The finding left some participants unnamed; those descriptions do not identify them with people in later cases.<ref name="r1" /><ref name="r9" />

	Later litigation supplied additional accounts of exchange-house transactions. A Foundation for Defense of Democracies (FDD) study reproduced a claim from the Bartlett lawsuit involving a $20,000 cash deposit by Abdul Latif Fawaz at New Line Exchange in 2008. According to that complaint, New Line then instructed LCB to debit its dollar account and transfer funds to an individual’s account at SGBL. This was a separate alleged transaction illustrating an exchange-to-bank payment sequence, rather than an identified Joumaa transfer.<ref name="r27" />		Later litigation supplied additional accounts of exchange-house transactions. A Foundation for Defense of Democracies (FDD) study reproduced a claim from the Bartlett lawsuit involving a $20,000 cash deposit by Abdul Latif Fawaz at New Line Exchange in 2008. According to that complaint, New Line then instructed LCB to debit its dollar account and transfer funds to an individual’s account at SGBL. This was a separate alleged transaction illustrating an exchange-to-bank payment sequence, rather than an identified Joumaa transfer.<ref name="r27" />