United Arab Emirates;
United Arab Emirates;
United Arab Emirates
Address
Unit 2808, Plot JLT-PH1-F2A, HDS Tower, Jumeirah Lakes Towers, Dubai, United Arab Emirates;
Unit AG-11-H, AG Tower, Plot JLT-PH1-I1A, Jumeirah Lakes Towers, Dubai, United Arab Emirates
Today, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) is taking additional action against Iranian military revenue generation, targeting Oceanlink Maritime DMCC for facilitating the shipment of Iranian commodities on behalf of Iran’s Armed Forces General Staff (AFGS) and Ministry of Defense and Armed Forces Logistics (MODAFL). OFAC is also identifying 13 vessels managed by Oceanlink Maritime DMCC as blocked property. The Oceanlink Maritime DMCC-managed vessel HECATE recently loaded Iranian commodities valued at over $100 million dollars via a ship-to-ship (STS) transfer from another sanctioned tanker, the DOVER, on behalf of Iran’s Sepehr Energy Jahan Nama Pars (Sepehr Energy), which OFAC sanctioned in November 2023 for its role selling Iranian commodities for the AFGS and MODAFL. Oceanlink Maritime DMCC operates a fleet of over one dozen vessels which are deeply involved in the shipment of Iranian commodities, including on behalf of Iran’s military. On March 25, 2024, the DOVER (IMO: 9218466), a vessel operated by NITC and carrying over $100 million worth of commodities on behalf of Sepehr Energy, conducted an STS transfer with the Comoros-flagged, Oceanlink Maritime-managed HECATE (IMO: 9233753), using obfuscation techniques to conceal the locations of the vessels.
Sepehr Energy has also shipped Iranian commodities using the Comoros-flagged ANTHEA (IMO: 9281683) and BOREAS (IMO: 9248497), both of which are managed by Oceanlink Maritime DMCC. Oceanlink Maritime DMCC also manages the Comoros-flagged CAPE GAS (IMO: 9002491), GLAUCUS (IMO: 9337389), OCEANUS GAS (IMO: 9397080), and HEBE (IMO: 9259185), the Antigua and Barbuda-flagged CALYPSO GAS (IMO: 9131101) and MERAKI (IMO: 9194139), the Belize-flagged ELSA (IMO: 9256468) and BAXTER (IMO: 9282522), the Panama-flagged DEMETER (IMO: 9258674) and the Cook Islands-flagged OUREA (IMO: 9350422). The CAPE GAS, GLAUCUS, OCEANUS GAS, HEBE, CALYPSO GAS, MERAKI, ELSA, BAXTER, DEMETER, and OUREA have all shipped Iranian commodities, some as recently as March of this year.
Oceanlink Maritime DMCC, which is based in the UAE, 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, Sepehr Energy. The HECATE, ANTHEA, BOREAS, CAPE GAS, GLAUCUS, OCEANUS GAS, HEBE, CALYPSO GAS, MERAKI, ELSA, BAXTER, DEMETER, and OUREA are being identified as property in which Oceanlink Maritime DMCC 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”).
