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2013 Section 311 action on Rmeiti and Halawi exchanges

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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.[1][2]

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.[1][2]

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.[1][2]

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.[3]

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.[1][2]

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.[2]

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.[4][2]

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.[5]

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.[1][2]

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.[6]

See also

References

Legal and sanctions status as of 14 September 2026.

TerrorWiki: Hezbollah-linked narcotics finance and illicit-finance networks
Hezbollah Funding of Hezbollah · Hezbollah · Hezbollah-linked narcotics finance
People Abbas Hussein Harb · Adel El Zabayar · Akram Saied Joumaa · Ali Mohamad Saleh · Ali Mohammed Kharroubi · Amer Mohamed Akil Rada · Ayman Joumaa · Chekri Mahmoud Harb · Dino Bouterse · Haitham Rmeiti · Hamdi Zaher El Dine · Hassan Ayash · Hassan Muhammad Daqqou · Henry Guberek Grimberg · Ibrahim Chibli · Iman Kobeissi · Isaac Perez Guberek Ravinovicz · Johanna Patricia Ceballos Bueno · Joseph Asmar · Kassem Chams · Khaldoun Hamieh · Luis Santiago Calle Quiros · Maria Paloma Rodriguez Badillo · Merhi Ali Abou Merhi · Mohamad Noureddine · Mohammad Ibrahim Bazzi · Noah Zaitar · Raji Falhout · Samer Akil Rada · Samer Kamal al-Assad · Siavosh Henareh
Organizations and networks Ayman Joumaa network · Barakat network · Chams Money Laundering Organization · Cheaitelly–El Khansa network · Guberek money-laundering network · Guberek network Spanish cell · Hezbollah Business Affairs Component
Banks and exchange houses Al-Qard al-Hasan · Ellissa Exchange Company · Halawi Exchange · Hassan Ayash Exchange Company · Kassem Rmeiti & Co. for Exchange · Lebanese Canadian Bank
Companies Abou Merhi Group · Abou-Merhi Lines · Caesar's Park Hotel · Ellissa Holding · Trade Point International
Criminal groups Cártel de los Soles in the El Zabayar case · FARC in the El Zabayar case · La Oficina de Envigado · Los Zetas in the Ayman Joumaa case · Sinaloa Cartel in the 2019 Chams designation
Investigations and operations Hezbollah Financing and Narcoterrorism Team · Operation Cedar · Operation Titan · Project Cassandra
Countries and regions Argentina and Triple Frontier financial investigations · Benin in the Joumaa exchange-house records · Colón Free Zone money laundering · Hezbollah finance in Brazil · Hezbollah finance in Paraguay · Hezbollah finance in the Triple Frontier · Hezbollah-linked narcotics finance in Colombia · Hezbollah-linked narcotics finance in Latin America · Latin America, West Africa and Lebanon in the Joumaa and LCB cases · South America, Europe and Lebanon in the 2016 DEA investigation · Transnational narcotics finance in Lebanon · Venezuela in the El Zabayar case · West Africa in the Lebanese Canadian Bank case
Money-laundering methods Black Market Peso Exchange · Bulk-cash movement in the Joumaa and LCB cases · Cocaine-proceeds laundering · Exchange houses in narcotics finance · Hawala disbursement in the 2016 European drug-money investigation · Professional money-laundering services · Shell-company accounts in the Guberek network · Trade-based money laundering · U.S. used-car exports to West Africa
Sanctions and law 2013 Section 311 action on Rmeiti and Halawi exchanges · Foreign Narcotics Kingpin Designation Act · Hizballah International Financing Prevention Act · Narcoterrorism · Section 311 of the USA PATRIOT Act
Captagon trade Captagon trafficking and Hezbollah · Syrian Fourth Division and Captagon