Tuesday, November 17, 2015

RUSSIA'S REFUSAL TO DESIGNATE HEZBOLLAH AS A TERRORIST ORGANIZATION IS A PROBLEM FOR COMPLIANCE


The Deputy Foreign Minister of Russia, Mikhail Bogdanov, has publicly stated that his country does not consider Hezbollah to be a terrorist organization. This disclosure was made in connection with Russia's efforts to negotiate a political solution to the civil war in Syria, where groups not considered terrorists will be reportedly involved in the negotiations. Russia has developed a relationship of sorts with Hezbollah, and is seeking to include it as a player, together with Iran, in deciding Syria's future.

Russia justifies its position based upon these grounds:
(1) Hezbollah has never committed any terrorist acts on Russian territory. This appears to be true.
(2) Hezbollah was elected by popular vote to the Lebanese Parliament.
(3) The Lebanese Government includes cabinet members, and ministers who are Hezbollah.
(4) Hezbollah is a "legitimate socio-political force" in Lebanon. Does this mean that its social programs excuse its terrorist actions ?

Given that both the United States and the EU long ago designated Hezbollah as a terrorist organization, the Russian position. Do not expect  the Western nations, especially the US and France, both of who lost soldiers and diplomats to terrorist acts linked to Hezbollah, in Lebanon, to change their positions.

Compliance officers should be vigilant, to insure that international trade transactions with their clients are not Russian fronts for Hezbollah purchases, through Russian banks. Any shipments of goods to Russian-controlled area of Syria (Latakia) could simply be transshipped to Hezbollah, within Syria. Given the take-no-prisoners attitude demonstrated by American regulators, towards any sanctions violations involving Hezbollah, you want to be careful with payments to your bank clients, originating in Russia, but for goods and services destined for the Middle East.

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