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Winter is coming for Hezbollah in Europe. The Iranian-backed Lebanese terrorist organization has been able to operate more openly on the continent than elsewhere because the European Union and most European governments subscribe to the fiction that Hezbollah has distinct military and political wings. Hezbollah itself denies that such an internal division exists, but it takes advantage of Europe’s permissive distinction to recruit and fundraise there. However, bipartisan legislation signed into law by the Trump administration may force the EU to act against Hezbollah. 

Europe has a Hezbollah problem. Alongside its clandestine operatives, Hezbollah maintains a more public international presence through its Foreign Relations Department (FRD). In 2013 the European Union blacklisted what it calls Hezbollah’s military wing in reaction to the terrorist organization’s July 2012 bombing of a bus in Burgas, Bulgaria, transporting Israeli tourists. The attack, which was perpetrated by Hezbollah operatives with Australian, Canadian, and French citizenship, killed 6 and injured more than two dozen people. An attempted attack in Cyprus by a Swedish citizen and Hezbollah member resulted in a conviction in 2013. Yet the FRD continues to operate, and the blacklisting of Hezbollah’s military wing has not put an end to clandestine activities.

Despite its name, the FRD is not an innocuous diplomatic organization. When designating FRD leader Ali Damush in January 2017, the State Department noted that the FRD “engages in covert terrorist operations around the world on behalf of Hizballah, including recruiting terrorist operatives and gathering intelligence.” Given that the FRD, as opposed to Hezbollah’s clandestine operatives, maintains a more public profile, its operations are presumably more easily identifiable to U.S. officials.  

Notwithstanding the European Union’s supposed distinction between Hezbollah’s military and political wings, the group’s operations in Europe and its record of fundraising and possibly recruitment there make Hezbollah’s military operations possible. For example, it was reported last year that the al-Mustafa Community Center in Bremen, Germany, is a major center for Hezbollah’s fundraising. 

The European Union’s reluctance to fully designate Hezbollah as a terrorist organization may no longer matter; the Union and any of its member states that have not fully designated Hezbollah may now in practice be forced to. In October 2018, U.S. President Donald Trump signed into law the Hizballah International Financing Prevention Act Amendments Act (HIFPAA). The Senate approved the bill by unanimous consent while the House affirmed it by voice vote. 

HIFPAA imposes secondary sanctions on the FRD. While the FRD is already sanctioned by the United States, secondary sanctions require the administration to sanction “any foreign person that the President determines knowingly provides significant financial, material, or technological support for or to” the FRD, in addition to other Hezbollah actors engaged in fundraising and recruitment. 

This could include any European individual or company that rents facilities to, provides banking services for, or any other action that aides a person or entity that is designated as FRD.  This means that, regardless of whether the EU blacklists all of Hezbollah or only part of it, European individuals and companies that knowingly provide material support to Hezbollah face U.S. sanctions.  

In effect, the “two wings” fiction will no longer protect Europeans from U.S. sanctions against Hezbollah. While Washington never recognized the distinction, U.S. law never before mandated the application of sanctions to other parties in Europe commercially interacting with the FRD.   

The European Union will now have to determine what it will do in response. The best move it could make would be to follow the example of the United Kingdom’s Home Secretary and designate Hezbollah in its entirety as a terrorist organization. However, if member states are unable to do so, an alternative would be to remain passive while U.S. sanctions take effect, and quietly urge the expulsion of Hezbollah’s “political wing.”     

In order to do so, EU members must effectively enforce the requirements of the HIFPAA to ensure that all offices and operations of facilitators of Hezbollah’s FRD offices are identified and shuttered. The U.S. and Europe may disagree on Iran policy, but we should agree on the simple question of shutting down Hezbollah’s terrorism in its totality. 

Matthew Zweig is a senior fellow at the Foundation for Defense of Democracies, where he contributes to FDD’s Center on Economic and Financial Power (CEFP). Matthew is a former Senior Professional Staff Member for the House Foreign Affairs Committee. The views expressed are the author’s own.