WASHINGTON — Today, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned eighteen companies, individuals, and vessels for their ties to Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF)-backed Houthi financial official Sa’id al-Jamal (al-Jamal) and his network. Included in this action are the captains of vessels transporting illicit oil as well as the companies that managed and operated these ships. The revenue from al-Jamal’s network continues to enable Houthi attacks in the region, including missile and unmanned aerial vehicle attacks on Israel and commercial vessels transiting the Red Sea.
“The Houthis remain reliant on Sa’id al-Jamal’s international network and affiliated facilitators to transport and sell Iranian oil, continuing their campaign of violence,” said Acting Under Secretary of the Treasury for Terrorism and Financial Intelligence Bradley T. Smith. “Treasury remains committed to utilizing all available tools to disrupt this key source of illicit revenue that enables the Houthis’ destabilizing activities.”
Today’s action is being taken pursuant to counterterrorism authority Executive Order (E.O.) 13224, as amended. OFAC designated al-Jamal pursuant to E.O. 13224, as amended, on June 10, 2021, for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, the IRGC-QF. OFAC designated the IRGC-QF pursuant to E.O. 13224 on October 25, 2007, for providing material support to multiple terrorist groups. The U.S. Department of State’s designation of Ansarallah (commonly known as the Houthis) as a Specially Designated Global Terrorist (SDGT), pursuant to E.O. 13224, as amended, became effective on February 16, 2024.
SPRAWLING ILLICIT sHIPPING network
The al-Jamal network relies on a network of front companies and willing partners in multiple jurisdictions to facilitate the sale of Iranian petroleum and petroleum products for the benefit of the Houthis. For example, in late 2023, the Panama-flagged crude oil tanker KAPOK (IMO 9315654), owned by Marshall Islands-registered Changtai Shipping Ltd, transported over a million barrels of crude oil, worth tens of millions of dollars, on behalf of al-Jamal and sanctioned Türkiye-based, Houthi-associated businessman Abdi Nasir Ali Mahamud.
Changtai Shipping Ltd is being designated pursuant to E.O. 13224, as amended, for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, al-Jamal. The KAPOK is being identified as blocked property in which Changtai Shipping Ltd has an interest.
Similarly, Marshall Islands-based Motionavigations Limited and United Arab Emirates-based Indo Gulf Ship Management LLC served as the registered owner and operator, respectively, of a vessel that was used by the al-Jamal network to ship several millions of dollars’ worth of Iranian fuel oil.
UAE-based Ukrainian national Yevhen Skriabin owns and operates Motionavigations Limited, in addition to UAE-based companies Eco Max Trading FZE and Eco Max FZE. Established in June of 2019, Eco Max Trading FZE registered its subsidiary Eco Max FZE in 2020 to operate its maritime-related business. As part of this business, Eco Max FZE operates and manages multiple vessels, including the Cook Islands-flagged vessels MARBEL (IMO 9220938), TROPHY (IMO 9220940), and ONYX (IMO 9252400), and the Palau-flagged vessels LIANA (IMO 9236755), GRATIA (IMO 9260055), and the JUVENIS (IMO 9260067). The MARBEL, TROPHY, and LIANA have all been linked to illicit Iranian oil shipments.
UAE and India-based Indian national Rahul Rattanlal Warikoo Rattanlal acts as the managing director of Indo Gulf Ship Management LLC. Rattanlal has served in management roles for U.S.-designated companies Safe Seas Ship Management FZE and Aurum Ship Management FZC, which have been implicated in Iranian oil shipments for Iran’s Ministry of Defense and Armed Forces Logistics (MODAFL) and the al-Jamal network. Hong Kong and India-based Indian national Dipankar Mohan Keot (Keot) serves as the technical manager of Indo Gulf Ship Management LLC. In this role, Keot is responsible for monitoring vessel operations, including the budget and expenditure of the vessels under Indo Gulf Ship Management LLC’s oversight.
Indo Gulf Ship Management LLC currently serves as the manager and operator of the Barbados-flagged KUKKI (IMO 9247388).
Motionavigations Limited and Indo Gulf Ship Management LLC are being designated pursuant to E.O. 13224, as amended, for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or service to or in support of al-Jamal.
Yevhen Skriabin is being designated pursuant to E.O. 13224, as amended, for owning or controlling, directly or indirectly, Motionavigations Limited.
Eco Max Trading FZE is being designated pursuant to E.O. 13224, as amended, for being owned, controlled, or directed by, directly or indirectly, Yevhen Skriabin. Eco Max FZE is being designated pursuant to E.O. 13224, as amended, for being owned, controlled, or directed by, directly or indirectly, Eco Max Trading FZE. The MARBEL, TROPHY, ONYX, LIANA, GRATIA, and the JUVENIS are being identified pursuant to E.O. 13224, as amended, as property in which Eco Max FZEhas an interest.
Rahul Rattanlal Warikoo Rattanlal and Dipankar Mohan Keot are being designated pursuant to E.O. 13224, as amended, for having acted or purported to act for or on behalf of, directly or indirectly, Indo Gulf Ship Management LLC. The KUKKI is being identified as property in which Indo Gulf Ship Management LLC has an interest.
vessel captains
The al-Jamal network is not only reliant on its system of companies, managers, and vessels to transport Iranian commodities, but also on the individuals who oversee these shipments.
In mid-August, Iranian national Ali Barkhordar, while acting as the master of the U.S.-sanctioned vessel YORGOS, formerly known as the OHAR and ARTURA, conducted a ship-to-ship transfer with the U.S.-sanctioned Guyanese-flagged vessel OLYMPICS, previously known as the LADY SOFIA, captained by Pakistani national Wahid Ullah Durrani, to load sanctioned oil cargo on behalf of al-Jamal.
Ali Barkhordar and Wahid Ullah Durrani are being designated pursuant to E.O. 13224, as amended, for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, al-Jamal.
SANCTIONS IMPLICATIONS
As a result of today’s action, all property and interests in property of these individuals and entities named above, and of any entities that are owned, directly or indirectly, 50 percent or more by them, individually, or with other blocked persons, that are in the United States or in the possession or control of U.S. persons must be blocked and reported to OFAC. OFAC’s regulations generally prohibit all dealings by U.S. persons or within the United States (including transactions transiting the United States) that involve any property or interests in property of designated or blocked persons. U.S. persons must comply with OFAC regulations, including all U.S. citizens and permanent resident aliens regardless of where they are located, all persons within the United States, and all U.S.-incorporated entities and their foreign branches. Non-U.S. persons are also subject to certain OFAC prohibitions. For example, non-U.S. persons are prohibited from causing or conspiring to cause U.S. persons to wittingly or unwittingly violate U.S. sanctions, as well as engaging in conduct that evades U.S. sanctions. Violations of OFAC regulations may result in civil or criminal penalties. OFAC may impose civil penalties for sanctions violations based on strict liability, meaning that a person subject to U.S. jurisdiction may be held civilly liable even if such person did not know or have reason to know that it was engaging in a transaction that was prohibited under sanctions laws and regulations administered by OFAC. OFAC’s Economic Sanctions Enforcement Guidelines provide more information regarding OFAC’s enforcement of U.S. economic sanctions, including the factors that OFAC generally considers when determining an appropriate response to an apparent violation. For additional information on complying with U.S. sanctions and export control laws, please see Department of Commerce, Department of the Treasury, and Department of Justice Tri-Seal Compliance Note.
Furthermore, engaging in certain transactions with the individuals designated today entails risk of secondary sanctions pursuant to E.O. 13224, as amended. Pursuant to this authority, OFAC can prohibit or impose strict conditions on the opening or maintaining in the United States of a correspondent account or a payable-through account of any foreign financial institution that knowingly conducted or facilitated any significant transaction on behalf of a Specially Designated Global Terrorist.
The power and integrity of OFAC sanctions derive not only from OFAC’s ability to designate and add persons to the SDN List, but also from its willingness to remove persons from the SDN List consistent with the law. The ultimate goal of sanctions is not to punish, but to bring about a positive change in behavior. For information concerning the process for seeking removal from an OFAC list, including the SDN List, please refer to OFAC’s Frequently Asked Question 897 here. For detailed information on the process to submit a request for removal from an OFAC sanctions list, please click here.
Click here for more information on the individual and entities identified today.
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