By: David Williams, Editor, ACSS
July 23, 2021
The U.S. has stepped up its efforts to thwart attempts to conduct business with individuals and companies that support aggressive, dissident groups in Iran and Yemen.
OFAC has designated members of a smuggling network that helps fund Iran’s Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF) and the Houthis in Yemen. The network, led by Sa’id al-Jamal, a Yemen national based in Iran, generates tens of millions of dollars in revenue from the sale of commodities, such as Iranian petroleum. OFAC says the proceeds are directed through intermediaries and exchange houses in multiple countries to the Houthis in Yemen.
The designations were announced on June 10 under the 2001 counterterrorism authority E.O. 13224, as amended. The IRGC-QF itself was designated in 2007.
Since the beginning of the conflict in Yemen, OFAC says the Houthis have relied on support from IRGC-QF to fight against the internationally recognized Yemeni government. The Houthis conduct lethal attacks in Yemen, says OFAC, using ballistic missiles, explosives, naval mines and drones to strike not only military targets, but also population centers, infrastructure, and nearby commercial shipping in Saudi Arabia, along key international trade routes.
Sa’id al-Jamal is considered to be a financial conduit to the Houthis. OFAC says he fronts companies and vessels that smuggle Iranian fuel, petroleum products, and other commodities to customers throughout the Middle East, Africa and Asia. He maintains connections to Hizballah and has worked with it to send millions of dollars to support the Houthis, OFAC says.
Sa’id al-Jamal is currently not designated by the E.U., nor the U.K.
Cohort of Businessmen
Sa’id al-Jamal’s network comprises a cohort of businessmen of various nationalities at different locations. The cohort sells illicit Iranian goods abroad and gives the profits to the Houthis in Yemen and the IRGC-QF.
Other members of the cohort comprise:
- Abdi Nasir Ali Mahamud, U.K. national and Turkey-based, is described by OFAC as a “key business partner” and coordinates the smuggling of petrochemicals;
- Manoj Sabharwal, U.A.E.-based Indian national, maritime shipping professional;
- Hani ‘Abd-al-Majid Muhammad As’ad, Turkey-based Yemeni accountant;
- Jami’ ‘Ali Muhammad, Somali businessman based in Oman, procures vessels and facilitates shipping;
- Talib ‘Ali Husayn Al-Ahmad al-Rawi, Syrian national based in Istanbul, Turkey, transfers funds through exchange houses in Yemen; and
- Abdul Jalil Mallah, Greece- and Sweden-based Syrian national, transfers funds through exchange houses in Yemen.
|Designated! Network Financing Houthi Aggression in Yemen|
|AL-JAMAL, Sa’id Ahmad Muhammad||Yemen||Iran||Head of the network|
|MAHAMUD, Abdi Nasir Ali||U.K.||Istanbul, Turkey + U.A.E.||Financial intermediary, coordinates smuggling of petrochemicals, and manages Adoon General Trading FZE in U.A.E..|
|SABHARWAL, Manoj||India||Dubai, U.A.E.||Maritime shipping professional|
|AS’AD, Hani ‘Abd-al-Majid Muhammad||Yemen||Turkey||Accountant, manages finances|
|MUHAMMAD, Jami’ ‘Ali||Somali||Oman||Procures vessels, facilitates shipping|
|AL-RAWI, Talib ‘Ali Husayn Al-Ahmad||Syrian||Istanbul, Turkey||Transfers funds through exchanges houses in Yemen|
|MALLAH, Abdul Jalil||Syrian||Greece + Sweden||Transfers funds through exchanges houses in Yemen|
Chart prepared by ACSS, compiled with information from OFAC press release https://home.treasury.gov/news/press-releases/jy0221 and Designation https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions/20210610
Company and Vessel Designations
Other designations comprise the following companies:
- A.E.-based Adoon General Trading FZE;
- A.E.-based Adoon General Trading L.L.C.;
- Turkey-based Adoon General Trading Gida Sanayi Ve Ticaret Anonim Sirketi; and
- Yemen-based Swaid and Sons for Exchange Co.
Triple Success, a vessel sailing under the Gabon flag, has also been designated. The vessel has been used to smuggle Iranian petroleum products, says OFAC.
Note that all designations have the entry “secondary sanctions”. Secondary sanctions target foreign businesses and persons doing business with targeted regimes, persons, and organizations.
For example, if a Singapore shipping company buys a vessels from Jami’ ‘Ali Muhammad, it may be penalized by OFAC. This is true even when there is nothing in the dealings that involve the U.S., such as the use of its currency or the export or import of U.S. goods.
Further details identifying the individuals and entities designated are in the Specially Designated Nationals List Update.