United Arab Emirates;
Switzerland;
Switzerland;
India
Address
Unit Number 1606 to 1610, Floor 16, Tower X3, Jumeirah Bay Tower, Dubai, United Arab Emirates;
Jumeirah Lakes Tower, Unit Number 1606 to 1610, Jumeirah, Bay Tower X3 Plot No: JLT-PH2-X3A, 126422, Dubai, United Arab Emirates;
PO Box 126422, Dubai, United Arab Emirates;
Hirsernweg 11 Hergiswil, NW 6052, Switzerland;
Information Technology Park 25/517/14, Ananya Tower, MG Road 680001 Trichur, Kerala, India
Reg. ID
DMCC-31631, Business Registration Number;
CHE-418.995.816, National ID No.;
CH-150.3.476.957-7, Trade License No.;
U52590KL2022FTC075362, Trade License No.
Official reason
As a result of U.S. sanctions, CGN Trade transferred its business operations to a closely affiliated company, UAE-based Transmart DMCC (Transmart), which also works to support illicit financial networks on behalf of the IRGC-QF. Transmart owner and CEO Zabi Vahap (Vahap) controls Transmart operations, having served a similar role with CGN Trade. Vahap and Adelina Kuliyeva, who holds power of attorney for both CGN Trade and Transmart, work closely with U.S.-designated IRGC-QF official Mohammad Sadegh Karimian (Karimian) to facilitate the sale of Iranian commodities to foreign buyers, proceeds of which have been sent to CGN Trade, Transmart, and Singapore-based MSE Overseas PTE. Ltd. (MSE Overseas). Transmart has laundered tens of millions of dollars as part of the network’s financial activity, including through the Iranian Embassy in Moscow. Mehboob Thachankandy Palikandy (Palikandy) was the manager and chief executive of CGN Trade and is also an employee of Transmart. Palikandy was involved in the liquidation of CGN Trade and its transfer of business operations to Transmart. He is also the owner and sole shareholder of MSE Overseas, Singapore-based Sealink Overseas PTE. Ltd., and UAE-based Solise Energy (FZE). Transmart DMCC 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, CGN Trade.
On June 6, 2003, OFAC issued the Global Terrorism Sanctions Regulations, 31 CFR part 594 (68 FR 34196, June 6, 2003 (“the Regulations”), to implement Executive Order (E.O.) 13224 of September 23, 2001, “Blocking Property and Prohibiting Transactions With Persons Who Commit, Threaten To Commit, or Support Terrorism” (66 FR 49079, September 25, 2001). OFAC has amended the Regulations on several occasions.
On September 9, 2019, 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 (22 U.S.C. 287c) (UNPA), issued E.O. 13886, “Modernizing Sanctions To Combat Terrorism” (84 FR 48041, September 12, 2019), effective September 10, 2019. In E.O. 13886, the President, finding it necessary to consolidate and enhance sanctions to combat acts of terrorism and threats of terrorism by foreign terrorists, terminated the national emergency declared in E.O. 12947 of January 23, 1995, “Prohibiting Transactions With Terrorists Who Threaten To Disrupt the Middle East Peace Process” (60 FR 5079, January 25, 1995), and revoked E.O. 12947, as amended by E.O. 13099 of August 20, 1998, “Prohibiting Transactions With Terrorists Who Threaten To Disrupt the Middle East Peace Process” (63 FR 45167, August 25, 1998). In addition, the President amended E.O. 13224, in order to build upon initial steps taken in E.O. 12947, to further strengthen and consolidate sanctions to combat the continuing threat posed by international terrorism, and in order to take additional steps to deal with the national emergency declared in E.O. 13224, with respect to the continuing and immediate threat of grave acts of terrorism and threats of terrorism committed by foreign terrorists, which include acts of terrorism that threaten the Middle East peace process.
Section 1 of E.O. 13886 replaces in its entirety section 1 of E.O. 13224, which had been amended by a number of prior Executive orders (E.O. 13224, as amended by all such authorities, is referred to herein as “amended E.O. 13224”), but does not amend the Annex to E.O. 13224, which was previously amended by E.O. 13268 of July 2, 2002, “Termination of Emergency With Respect to the Taliban and Amendment of Executive Order 13224 of September 23, 2001” (67 FR 44751, July 3, 2002) (“amended Annex to E.O. 13224”).
