On March 26, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control sanctioned one individual, six entities and two tankers for their alleged roles in facilitating financial transactions or commodity shipments for the Islamic Revolutionary Guard Corps-Qods Force (“IRGC-QF”), the Houthis, and Hizballah. This is the sixth round of sanctions since December 2023 targeting the network of Sa’id al-Jamal, an IRGC-QF-backed Houthi financial facilitator who was designated by the United States in 2021 under the counterterrorism authority of Executive Order 13224, as amended. According to OFAC, al-Jamal’s network has facilitated the shipment of Iranian commodities using a web of companies and vessels that forge shipping documents and use other deceptive practices to evade sanctions.
The new designees include four shipping companies based in Liberia, India, and Vietnam as well as two tankers — the Abyss and the Dawn II — that are owned by the newly designated entities, and were allegedly used to ship Iranian commodities. OFAC also designated Tawfiq Muhammad Sa’id al-Law, a Syrian money exchanger based in Lebanon, along with two Kuwait-based companies that al-Law used to transfer funds for the purchase of goods supporting al-Jamal’s network. According to OFAC, al-Law provided Hizballah with digital wallets that enabled the group to receive funds from IRGC-QF commodity sales, and also conducted cryptocurrency transfers for previously designated individuals and entities, including Hizballah officials Muhammad Qasim al-Bazzal and Muhammad Ja’far Qasir, who were listed as Specially Designated Global Terrorists (“SDGTs”) in 2018.
The new designations were imposed pursuant to EO 13224, as amended, which targets terrorist groups and their supporters. As a result of these designations, all property and interests in property of the designated persons within the United States or within the possession or control of a U.S. person are blocked, and U.S. persons are generally prohibited from engaging in transactions involving a designated person. Entities owned 50 percent or more by one or more blocked persons are also blocked.