Sanctions Round Up First Quarter 2022

Shearman & Sterling LLP

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11 web of intermediaries to fund Houthi attacks in the years-long proxy war in Yemen. OFAC designated three commodity traders, Mahamud, Abdo Abdullah Dael Ahmed, and Konstantinos Stavridis, all based in the UAE, for financing the Houthis. Ahmed reportedly operates a Yemen-based entity Moaz Abdalla Dael Import and Export, through which he has transferred over $10 million to al-Jamal. Stavridis uses his company, Fani Oil Trading FZE, to purchase gasoline for al-Jamal. OFAC further designated Mahamud's company, Turkey-based JJO General Trading Gida Sanayi Ve Ticaret Anonim Sirketi, and Dael's company, UAE-based Al Foulk General Trading Co LLC. Additionally, OFAC designated Turkey-based intermediary Garanti Ihracat Ithalat Kuyumculuk Dis Ticaret Limited Sirketi for facilitating millions of dollars of transactions for al-Jamal in support of oil shipments to China and Syria. OFAC further designated Yemen-based money exchange houses AlAlamiyah Express Company for Exchange and Remittance and Al-Hadha Exchange Co. for having moved millions of dollars for al-Jamal. Finally, in the same round of sanctions, OFAC designated India, Singapore, and UAE-based Aurum Ship Management FZC, a shipping company connected to al-Jamal and Mahamud, and a vessel operating under the flag of St. Kitts and Nevis, Light Moon. According to OFAC, Light Moon was used to ship petroleum products in support of Mahamud and tried to disguise its activities by turning off its Automatic Identification System. OFAC also designated Aurum's managing director, Chiranjeev Kumar Singh, and a shell company Peridot Shipping and Trading LLC. On March 1, OFAC designated financiers of ISIS and ISIS-Mozambique based in South Africa. According to OFAC Durban-based Farhad Hoomer provided residential properties and vehicles to support a South Africa-based cell of ISIS. He also raised funds through kidnapping and extortion. OFAC also designated the leader of a Cape Town-based group of ISIS supporters, Siraaj Miller, a supporter of ISIS-Mozambique who facilitated funds transfers to it, Peter Charles Mbaga, and the owner of two mosques in South Africa who extorted their members for funds for ISIS, Abdella Hussein Abadigga. In continuing its trend of sanctions enforcement against financers of terrorism, OFAC designated two key Hizballah financiers operating in Guinea on March 4. According to OFAC, Ali Saade and Ibrahim Taher, Lebanese businessmen, transfer funds through Hizballah representatives in Guinea and Lebanon. Saade is reportedly closely tied to previously designated Hizballah supporter Kassem Tajideen. On March 7, OFAC and the State Department designated Katibat al Tawhid wal Jihad (KTJ). KTJ is an al-Qaeda affiliate that operates in the Idlib province of Syria with Hay'at Tahrir al-Sham, Katibat al-Imam al-Bukhari, and Islamic Jihad Group. According to the State Department, KTJ is responsible for terrorist attacks in Syria, as well as the 2017 St. Petersburg metro attack in April of 2017 and the car bombing of the Chinese Embassy in Bishkek, Kyrgyzstan in 2016. On March 25, OFAC designated Abdurrahman Ado Musa, Salihu Yusuf Adamu, Bashir Ali Yusuf, Muhammed Ibrahim Isa, Ibrahim Ali Alhassan, and Surajo Abubakar Muhammad for their affiliation with Nigeria-based terrorist group Boko Haram. Recently, the UAE Federal Court of Appeals in Abu Dhabi convicted everyone for transferring $782,000 from Dubai to Boko Haram. They have all been sentenced in the UAE, with Adamu and Muhammad receiving life imprisonment. OFAC intends for these sanctions to prevent the further use of the individuals' funds in support of terrorism.

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