Similarly, Marshall Islands-based Motionavigations Limited and United Arab Emirates-based Indo Gulf Ship Management LLC served as the registered owner and operator, respectively, of a vessel that was used by the al-Jamal network to ship several millions of dollars’ worth of Iranian fuel oil. UAE and India-based Indian national Rahul Rattanlal Warikoo Rattanlal acts as the managing director of Indo Gulf Ship Management LLC. Rattanlal has served in management roles for U.S.-designated companies Safe Seas Ship Management FZE and Aurum Ship Management FZC, which have been implicated in Iranian oil shipments for Iran’s Ministry of Defense and Armed Forces Logistics (MODAFL) and the al-Jamal network. Hong Kong and India-based Indian national Dipankar Mohan Keot (Keot) serves as the technical manager of Indo Gulf Ship Management LLC. In this role, Keot is responsible for monitoring vessel operations, including the budget and expenditure of the vessels under Indo Gulf Ship Management LLC’s oversight. Indo Gulf Ship Management LLC currently serves as the manager and operator of the Barbados-flagged KUKKI (IMO 9247388). Motionavigations Limited and Indo Gulf Ship Management LLC 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 service to or in support of al-Jamal. Rahul Rattanlal Warikoo Rattanlal and Dipankar Mohan Keot are being designated pursuant to E.O. 13224, as amended, for having acted or purported to act for or on behalf of, directly or indirectly, Indo Gulf Ship Management LLC. The KUKKI is being identified as property in which Indo Gulf Ship Management LLC has an interest.
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”).
