2013 Section 311 action on Rmeiti and Halawi exchanges

Editorial illustration: 2013 Section 311 action on Rmeiti and Halawi exchanges

Original editorial illustration of exchange-house records and regulatory paperwork, not a specific transaction.

In April 2013, the U.S. Treasury identified Kassem Rmeiti & Co. for Exchange and Halawi Exchange Co. as foreign financial institutions of primary money-laundering concern under Section 311 of the USA PATRIOT Act. Treasury said the two exchange houses had taken over laundering work associated with the Joumaa network after earlier U.S. actions against Lebanese Canadian Bank and other exchanges. FinCEN issued an immediate, 120-day reporting order and a proposed rule for further measures. The 2013 finding, order and proposal are distinct legal actions; their historical description here does not assert that a proposed measure became a permanent rule.

Historical action

Treasury said this was the first use of Section 311 against non-bank financial institutions. Its release described Rmeiti and Halawi as processing funds for traffickers and money launderers, including used-car trade-related flows, and stated that laundering in these networks provided substantial benefits to Hezbollah. FinCEN’s Rmeiti notice recorded a finding effective April 22, 2013. A Section 311 finding is a regulatory assessment; it is not a conviction of an exchange or its customers.

Attributed role

Treasury said FinCEN issued an order effective immediately requiring U.S. financial institutions to report new or attempted transactions involving the two exchanges for 120 days. It also described a notice of proposed rulemaking that, if finalized, would continue reporting and prohibit certain correspondent or payable-through accounts. The proposal should be described as proposed in this 2013 record. This historical account does not establish the present status of those measures.

What the temporary order required

The published Halawi order specified a period from 23 April to 21 August 2013. It applied to covered financial institutions and registered principal money transmitters asked to process transactions involving Halawi. Reporting covered attempted as well as completed transactions, participants’ identities and addresses, the capacity in which Halawi acted, the customer represented and the transaction’s purpose. This was a requirement to collect information during a stated period, distinct from the proposed further restrictions.

Related case record

The release attributed at least $25 million in payments by Rmeiti Exchange and its owner to U.S. car dealers/exporters associated with Joumaa between 2008 and March 2011. It also described Halawi’s Benin-related wires and Cotonou-to-Beirut bulk cash route, and asserted that Halawi laundered cocaine-related profits for a leading Hezbollah official and narcotics trafficker. These are specific agency assertions about different channels and periods; their amounts should not be added as one flow.

Replacement channels

FinCEN’s Rmeiti finding described February 2011 creation of TAG, employment of former Ellissa staff and use of Swiss WCS accounts. It alleged that 30–40 percent of TAG’s profits were to go to Ali Kharroubi. That percentage concerned TAG’s profit-sharing arrangement, not the share of every transfer paid to Hezbollah. The finding separately described Haitham Rmeiti as having replaced Kharroubi as a facilitator by December 2011. These details explain the agency’s claim that activity adapted after the earlier action.

Amounts and proposed business

The Halawi finding distinguished more than $4 million in early-2012 wires associated with a Benin used-car business from contracts proposing another $224 million in business. A planned volume is not an executed transfer total. FinCEN also described shared transfers by Rmeiti, Halawi and other exchange houses; such shared figures should not be assigned in full to each institution or added repeatedly.

Responses

Contemporary Daily Star reporting said Rmeiti rejected the accusation and challenged the evidence. Halawi said it complied with Lebanese requirements and kept client and source-of-funds documentation. These were the businesses’ responses to the action. They remain distinct from FinCEN’s allegations and from a judicial resolution of them.

Scope and distinctions

The 2013 Section 311 action followed separate 2011 Kingpin Act designations against Joumaa and earlier exchanges and a prior Section 311 action concerning Lebanese Canadian Bank. This page describes the agency finding, temporary reporting order and proposed rule as of their announcement. It does not convert an exchange-house assessment into personal guilt of every customer or employee, nor does it identify every used-car transaction as Hezbollah financing.

Financial adaptation

Binstok, Mizrahi and Klor’s May 2026 INSS analysis describes interchangeable money changers and intermediaries, with cash, goods and hawala offsets used in financial settlement. Their interpretation helps explain the problem Treasury sought to address when it alleged replacement channels after the LCB action. It does not establish a final rule, the results of every reported transaction, or a new individual offense.

See also

• Hezbollah Business Affairs Component
• Lebanese Canadian Bank

References

Legal and sanctions status as of 14 September 2026.