As of 2014, Abdulwahab Noor Abdi (Abdi), also known as “Tomato,” had brokered the charter for a charcoal delivery to Oman from al-Shabaab-controlled territory in Somalia. Abdi’s operations have been referred to by locals as “Iskaashatada Yaanyo,” or the “Tomato Association.”
Naaji, Abdi’s business partner, has sent funds to Abdi totaling approximately $200,000. Both Abdi and Naaji have also previously collected funds for al-Shabaab.
Abdi is a five percent shareholder in and has been the General Manager of Al Nezam Al Asasy General Trading L.L.C since 2017. Abdi was also previously the Director of Al Nezam Al Asasy General Trading L.L.C since 2012.
Al Nezam Al Asasy General Trading L.L.C has separately received nearly $200,000 from Naaji. Between 2020 and 2022, Al Nezam Al Asasy General Trading L.L.C and Jamame Brothers Company have been involved in receiving at least ten Somali charcoal shipments in the UAE.
Abdi is being designated pursuant to E.O. 13536, as amended, for having engaged, directly or indirectly, in the import or export of charcoal from Somalia on or after February 22, 2012. Al Nezam Al Asasy General Trading L.L.C is being designated pursuant to E.O. 13536, as amended, for being owned or controlled, directly or indirectly, by Abdi.
On May 5, 2010, OFAC issued the Somalia Sanctions Regulations, 31 CFR part 551 (75 FR 24394, May 5, 2010) (the “Regulations”), to implement Executive Order (E.O.) 13536 of April 12, 2010, “Blocking Property of Certain Persons Contributing to the Conflict in Somalia” (75 FR 19869, April 15, 2010), pursuant to authorities delegated to the Secretary of the Treasury in E.O. 13536. The Regulations were initially issued in abbreviated form for the purpose of providing immediate guidance to the public. OFAC is revising the Regulations to further implement E.O. 13536 and to implement E.O. 13620 of July 20, 2012, “Taking Additional Steps to Address the National Emergency With Respect to Somalia” (77 FR 43483, July 24, 2012), which amended E.O. 13536. OFAC is amending and reissuing the Regulations as a more comprehensive set of regulations that includes additional interpretive and definitional guidance, general licenses, statements of licensing policy, and other regulatory provisions that will provide further guidance to the public. Due to the number of regulatory sections being updated or added, OFAC is reissuing the Regulations in their entirety.
E.O. 13536. On April 12, 2010, the President, invoking the authority of, inter alia, the International Emergency Economic Powers Act (50 U.S.C. 1701–1706) (IEEPA) and the United Nations Participation Act, as amended (22 U.S.C. 287c) (UNPA), issued E.O. 13536. In E.O. 13536, the President found that the deterioration of the security situation and the persistence of violence in Somalia, and acts of piracy and armed robbery at sea off the coast of Somalia, and violations of a United Nations arms embargo, constitute an unusual and extraordinary threat to the national security and foreign policy of the United States and declared a national emergency to deal with that threat.
