As of mid-2022, a Gulf-based network of individuals and companies were blending and exporting Iranian oil in support of Hizballah and the IRGC-QF. Viktor Artemov, Edman Nafrieh, Rouzbeh Zahedi, and Mohamed El Zein leveraged dozens of companies under their control to conduct the network’s illicit activities. The network used storage units in the Port of Sharjah in the United Arab Emirates, and blended products of Indian origin with Iranian oil to obfuscate the Iranian origin. The companies then modified or created counterfeit certificates of origin and quality for the blended oil, which was then transferred for sale abroad. Iranian national Rouzbeh Zahedi (Zahedi) also worked with the network to help transport the Iranian oil abroad and procure funds on behalf of Hizballah and the IRGC-QF. Zahedi used his companies to transfer funds to IRGC-QF and Hizballah members and coordinated activities closely with Mohamed El Zein (El Zein), a Hizballah member who was also part of the oil smuggling network and the son of a high-ranking Hizballah communications director. El Zein used forged invoices for consulting and shipping services from shell companies to hide the origin of financial transactions. Viktor Artemov, Edman Nafrieh, Rouzbeh Zahedi, and Mohamed El Zein 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, both Hizballah and the IRGC-QF. Gilda Tar Karvan International Company is being designated pursuant to E.O. 13224, as amended, for being owned or controlled by Edman Nafrieh.
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”).
