The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) is designating and identifying as blocked property a dozen persons and vessels, respectively, that have played a critical role in financing the Houthis’ destabilizing regional activities as part of the network of Sa’id al-Jamal.
This action includes Indonesia-based Malaysian and Singaporean national Mohammad Roslan Bin Ahmad and People’s Republic of China (PRC)-based Chinese national Zhuang Liang, who have facilitated illicit shipments and engaged in money laundering for the network.
Sa’id al-Jamal’s network continues to provide tens of millions of dollars in revenue to the Houthis in Yemen through its shipment of Iranian commodities, including oil, a funding stream underpinning the Houthis’ ongoing attacks against commercial shipping in the Red Sea.
This action targets numerous aspects of this illicit network across the spectrum of its operations, from clients and facilitators to insurance providers, vessels, and ship management firms.
“Today’s action underscores our focus on disrupting the Houthis’ sprawling network of financial facilitators, shell companies, and vessels, that enables the primary source of funding for the group’s destabilizing activities,” said Under Secretary of the Treasury for Terrorism and Financial Intelligence Brian Nelson.
“Treasury will continue disrupt the actors who are critical to this network’s operations, as well as the Houthis’ ability to further destabilize the region and threaten international commerce.”
Today’s action is being taken pursuant to the counterterrorism authority Executive Order (E.O.) 13224, as amended. OFAC designated Sa’id 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, Iran’s Islamic Revolutionary Guard Corps – Qods Force (IRGC-QF).
The IRGC-QF was designated pursuant to E.O. 13224 on October 25, 2007, for providing 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 group, pursuant to E.O. 13224, as amended, became effective on February 16, 2024.
Key International Illicit Finance And Shipping Facilitators
Malaysian and Singaporean national Mohammad Roslan Bin Ahmad (Royston), also known as Royston Wu Chiren or Mohammad Roslan Royston, is an Indonesia-based illicit shipment facilitator who provides ship management and brokering services for Sa’id al-Jamal’s network. Royston has facilitated the Sa’id al-Jamal network’s shipments to Malaysia. Royston has also brokered vessels for illicit Russian and Venezuelan trade.
PRC-based businessman Zhuang Liang (Zhuang) has engaged in money laundering and other finance-related schemes for the Sai’d al-Jamal network, including working with Sa’id al-Jamal and the IRGC-QF to further Sa’id al-Jamal’s illicit business operations. Zhuang has similarly assisted Sa’id al-Jamal business partner and Houthi-affiliate Abdi Nasir Ali Mahamud (Mahamud) in circumventing sanctions by illicitly providing him access to the international financial system.
OFAC designated Mahamud concurrently with Sa’id al-Jamal for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, Sa’id al-Jamal.
OFAC is updating Mahamud’s entry on the Specially Designated Nationals and Blocked Persons List (SDN List) to reflect his use of a Somali diplomatic passport, D00015633, to travel internationally. Sa’id al-Jamal has similarly traveled under the alias Ahmad Saeidi with Iran-issued passports U63475649 and E49297849, each of which is also being added to the SDN List today.
Zhuang and Royston 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, Sa’id al-Jamal.
ILLICIT SHIPPING NETWORK
Sa’id al-Jamal’s network relies on numerous, seemingly innocuous, companies in multiple jurisdictions to illicitly generate tens of millions of dollars of revenue. Seychelles- registered, Thailand and Singapore-based Ascent General Insurance Company has provided insurance to vessels that were identified as blocked property of those sanctioned for providing support to Sa’id al-Jamal.
United Arab Emirates (UAE)-based Fornacis Energy Trading Co. L.L.C has purchased and shipped tens of millions of dollars’ worth of Iranian cargo for the Sa’id al-Jamal network.
Ascent General Insurance Company and Fornacis Energy Trading Co. L.L.C 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, Sa’id al-Jamal.
Marshall Islands-registered and UAE-based Barco Ship Management Inc (Barco) is the ship manager and commercial manager of multiple vessels, including the Panama-flagged WANJI (IMO: 9215103), which has been utilized by Sa’id al-Jamal’s network for illicit shipments to the UAE worth tens of millions of dollars. Barco additionally manages and operates the Panama-flagged vessel OCEANIC II (IMO: 9275995) and the Panama-flagged vessel TIREX (IMO: 9203772).
Like Barco, the Marshall Islands-registered Sea Knot Shipping Inc. has used the vessel MIROVA DYNAMIC (IMO: 9237618) to transport illicit shipments worth tens of millions of dollars for Sa’id al-Jamal.
Barco and Sea Knot Shipping Inc. 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, Sa’id al-Jamal.
The WANJI, OCEANIC II, and TIREX are being identified as blocked property in which Barco has an interest. MIROVA DYNAMICis being identified as blocked property in which Sea Knot Shipping Inc.has an interest.
UAE-based Alpha Shine Marine Services L.L.C is the ship manager of the Panama-flagged vessel KASPER (IMO: 9293143), which has been used by the Sa’id al-Jamal network to facilitate millions of dollars’ worth of illicit trade under forged shipping documents.
Alpha Shine Marine Services L.L.Cis 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, Sa’id al-Jamal. The KASPER is being identified as blocked property in which Alpha Shine Marine Services L.L.C has an interest.
SANCTIONS IMPLICATIONS
As a result of today’s action, all property and interests in property of the designated persons described above that are in the United States or in the possession or control of U.S. persons are blocked and must be reported to OFAC.
In addition, any entities that are owned, directly or indirectly, individually or in the aggregate, 50 percent or more by one or more blocked persons are also blocked. Unless authorized by a general or specific license issued by OFAC, or exempt, OFAC’s regulations generally prohibit all transactions by U.S. persons or within (or transiting) the United States that involve any property or interests in property of designated or otherwise blocked persons.
In addition, financial institutions and other persons that engage in certain transactions or activities with the sanctioned entities and individuals may expose themselves to sanctions or be subject to an enforcement action.
The prohibitions include the making of any contribution or provision of funds, goods, or services by, to, or for the benefit of any designated person, or the receipt of any contribution or provision of funds, goods, or services from any such person.
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.