Iran-based Houthi financial facilitator Sa’id al-Jamal (al-Jamal) has for years relied on an array of exchange houses, both in Yemen and abroad, to remit the proceeds of Iranian commodity sales to the Houthi movement and IRGC-QF. Bilal Hudroj (Hudroj) of Lebanon-based Hodroj Exchange S.A.R.L. (Hodroj Exchange) has worked with al-Jamal to make financial transfers to Houthi officials in Yemen. Hudroj and Hodroj Exchange have sent millions of dollars and euros to Yemeni exchange houses aligned with al-Jamal, including Al Hadha Exchange Co. and AlAlamiyah Express Company for Exchange and Remittance, both of which were previously designated on February 23, 2022, 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, al-Jamal. At least some of these payments were made in direct coordination with senior Houthi members.
Hudroj and Hodroj Exchange have coordinated some of these financial transfers with Türkiye-based jewelry store and money exchanger Pirlant Istanbul Kuyumculuk Ticaret Limited Sirketi (Pirlant), also known as Jawhirah Exchange, and its owner Ahmet Duri (Duri). Duri has handled millions of dollars’ worth of transactions on behalf of al-Jamal’s network. Iranian money flowing to Yemen is deposited with Pirlant before eventually being transferred to Houthi-associated exchange houses in Yemen, including millions of dollars deposited by the IRGC in this fashion. The IRGC was designated on October 13, 2017, pursuant to E.O. 13224, for assisting in, sponsoring or providing financial, material, or technological support for, or financial or other services to or in support of, the IRGC-QF. Bilal Hudroj, Ahmet Duri, Pirlant Istanbul Kuyumculuk Ticaret Limited Sirketi, Abu Sumbol General Trading (L.L.C), Davos Exchange and Remittances Company (Khaled Al Athari and Partner) General Partnership, and Khaled Yahya Rageh Alodhari are all being designated pursuant to E.O. 13224, for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, Sa’id al-Jamal.
Hodroj Exchange S.A.R.L. is being designated pursuant to E.O. 13224, for being owned, controlled, or directed by, directly or indirectly, Bilal Hudroj.
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”).
