Trust Company Complex, Ajeltake Island, Majuro, 96960, Marshall Islands
Reg. ID
113880, Registration Number
Official reason
Hermex International Corporation
These companies have collectively moved hundreds of millions for dollars’ worth of revenue for MODAFL related to oil and petrochemical sales or foreign currency exchange operations. Between June 2022 and 2023, MODAFL used Atvantic Wholesalers L.L.C., Brighten Star FZE, and Gainon Co., Limited to make transfers worth nearly $10 million through Ansar Exchange. In September 2023, Meishur Limited transferred approximately $30 million to U.S.-designated Sepehr Energy Jahan Nama Pars Company, a key entity overseeing the foreign sale of oil on behalf of Iran’s AFGS.
Between May and October 2023, Meishur Limited, Turpami Limited, and Xaster Co., Limited transferred approximately $40 million collectively to Sahara Thunder on behalf of MODAFL. In October 2023, Caregis Trading HK Limited and Lzmar Trading Limited received $8 million and $15 million each from Sahara Thunder.
Kuwan Co., Limited has used the international financial system to make hundreds of transfers totaling over $30 million to numerous companies, including U.S.-designated unmanned aerial vehicle (UAV) parts suppliers Skyline Advanced Technologies SDN BHDand Nava Hobbies SDN BHD and transfers totaling approximately $500,000 to U.S.-designated Iranian military procurement front company FY International Trading Co., Limited. In January 2022, Cherry Star Co. Limited transferred approximately 15 million euro to the IRGC Oil Command on behalf of MODAFL.
The above entities are all 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, MODAFL.
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”).
