Today, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned more than a dozen entities and vessels for their involvement in the shipment of Iranian crude oil and liquid petroleum gas to Syria and East Asia on behalf of the Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF) and Hizballah. Among the vessels sanctioned today are four ships associated with the fleet of illicit shipping Syrian magnate Abdul Jalil Mallah (Abdul Jalil) and his brother Luay al-Mallah. Since Abdul Jalil’s June 10, 2021 designation for his support to the network of IRGC-QF-backed Houthi financial official Sa’id al-Jamal, Luay al-Mallah has continued to use their shipping empire to support Iran’s malign activities and those of its proxies. Luay al-Mallah is also being designated in this action. Luay al-Mallah has assisted his brother, sanctioned Syrian shipping magnate Abdul Jalil Mallah, in running his family’s business following the latter’s designation for assisting the illicit shipping network of Sa’id al-Jamal, an IRGC-QF-backed Houthi financial official. The Mallah family’s ships, including the Panama-flagged CONFIDENCE P (IMO: 9178044), Sao Tome and Principe-flagged NOVA (IMO: 9141259), Panama-flagged RIVAL (IMO: 9117818), and Iran-flagged TIYARA (IMO: 9231224), have facilitated illicit trade between Syria and Iran for the benefit of the IRGC-QF and Hizballah. As recently as 2021, Luay al-Mallah managed a shipment for Sa’id al-Jamal. In 2021, Sa’id al-Jamal’s network used the NOVA and TIYARA to facilitate illicit trade between Iran and Syria. Luay al-Mallah owns the Abdul Jalil Mallah-directed, Türkiye-based Oryx Denizcilik Limited Sirketi. Luay al-Mallah 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, Abdul Jalil Mallah. Oryx Denizcilik Limited Sirketi is being designated pursuant to E.O. 13224, as amended, for being owned, controlled, or directed by, directly or indirectly, Luay al-Mallah. CONFIDENCE P, NOVA, RIVAL, and TIYARA are being identified as property in which Abdul Jalil Mallah 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”).
