EU Lebanon Sanctions: Who Will Be On The List?

On Friday the EU announced that it will implement Lebanon-focused sanctions. The new legal authority, with no one yet named under it, will focus on those that:

• Obstruct or undermine the democratic political process

• Obstruct or undermine [...] accountability and good governance in the public sector or the implementation of critical economic reforms

• Engage in serious financial misconduct concerning public funds

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Announcing new sanctions powers without adding any names to a list is actually common, and serves as a final warning shot to those engaged in sanctionable behavior. The EU sent over $1 billion in aid to Lebanon in the last decade, but much of this money has been stolen by corrupt officials in Lebanon. The EU has had enough and is shifting from carrots to sticks.

So, who will the EU sanction for destabilizing Lebanon? It will start by examining who is already on similar lists. To replicate the EU’s decision-making process, Castellum.AI examined global sanctions lists to see how many designees have are Lebanese (Lebanese citizenship, place of birth or address), and the bad news for Lebanon is that the EU has a lot of names to choose from. 

• 11 countries, the EU and UN have sanctions on Lebanese individuals and entities

  • US OFAC SDN

  • Australia DFAT

  • EU Sanctions

  • France Tresor Registre Des Gels

  • Indonesia DTTOT

  • Qatar NCTC

  • Switzerland SECO

  • UK HMT OFSI

  • Ukraine SFMS

  • Argentina RePET

  • Canada United Nations Act

  • New Zealand Designated Terrorist Entities

  • UN Sanctions

• 282 Lebanese individuals and entities have been sanctioned.

• Over 300 total designations as some of these individuals and entities have been sanctioned by multiple different authorities. For example, terrorist Adham Husayn Tabaja has been sanctioned by Argentina, Qatar and the United States.

• 30+ reasons for why sanctions were imposed, including human rights abuse, destabilizing Lebanon’s democracy, Iranian regime activities, narco-trafficking, terrorism, nuclear proliferation and even interference in US elections.

A key flashpoint for the EU will be in deciding whether to take a hard line against Hizballah. Hizballah is sanctioned by Australia, Canada, Malaysia, the UK and US, but crucially not the EU and UN. (Some other countries have banned Hizballah, such as Germany, but these bans are done through law enforcement methods, and are not sanctions. Germany does not have its own sanctions list, instead relying on the EU). Of those sanctioned with Lebanese citizenships, places of birth or addresses:

• 100+ are related to Hizballah

Syria and Iran are also key contributors to Lebanon’s instability, and the EU will likely consider sanctions on these governments, however, they already have Syria and Iran sanctions programs.

Will EU sanctions achieve the goal of pushing Lebanese politicians to urgently fix the country’s ills? Unlikely. In 2007, the US sanctioned three Lebanese politicians for undermining Lebanese democracy, in 2020 a top politician and former foreign minister for corruption. What could be different this time is that the EU and US will likely work together on Lebanon-focused sanctions.

 Methodology

This data snapshot covers all available Lebanon-related designations and as such, has duplicate names. For the purposes of simplicity, this spreadsheet only shows one Lebanon-associated characteristic, i.e. citizenship, sanctions list, address, etc. Some designees are on a “Lebanon” list, have a Lebanese citizenship and have a Lebanese address. While some of the addresses are simply “Lebanon,” others have detailed street and city locations. If you would like the full data snapshot with all of the his information, please email us at contact@castellum.ai