Russia-based Afghan businessman Hushang Ghairat (Hushang) and his brother, Russia-based Afghan businessman Sohrab Ghairat (Sohrab) have assisted Sa’id al-Jamal with Houthi commercial initiatives in Russia, including arms procurement. In summer and fall 2024, Hushang and Sohrab, at Sa’id al-Jamal’s direction, orchestrated at least two shipments of stolen Ukrainian grain from Crimea to Yemen on board the Russia-flagged AM THESEUS (IMO: 9720263), also known as the ZAFAR. Hushang, Sohrab, AM Asia M6 Ltd, Vidanov, and Belyakov 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, Sa’id al-Jamal. The AM THESEUS is being identified as blocked property in which AM Asia M6 Ltd has an interest. Hushang, Sohrab, and Sa’id al-Jamal use financial facilitators to conduct financial transactions in support of the Houthis’ trade ventures involving Russia, including the aforementioned grain shipments. Turkiye-based Iranian money launderer Hassan Jafari (Jafari) has worked with Hushang and Sa’id al-Jamal to launder dollars on behalf of Sa’id al-Jamal’s network, enabling the network’s sanctions evasion schemes. Jafari also arranged payments worth millions of dollars in support of shipments benefiting the Houthis. Jafari 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, Hushang.
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”).
