Muhammad Al-Sunaydar (Al-Sunaydar), who manages a network of petroleum companies between Yemen and the United Arab Emirates, is one of the most prominent petroleum importers in Yemen. Al-Sunaydar manages Arkan Mars Petroleum Company for Oil Products Imports (Arkan Mars), which has an agreement with the Houthis to import gas and oil, including Iranian petroleum products, for the terrorist group through the Houthi-controlled Hudaydah and Ras Isa ports in Yemen. As of June 2025, Iranian-affiliated companies were involved in facilitating payments between the Iranian government and Houthi-affiliated oil companies, including Arkan Mars. As a part of Al-Sunaydar’s network, Arkan Mars Petroleum DMCC and Arkan Mars Petroleum FZE are UAE-based companies associated with Arkan Mars that have been involved in exporting oil to Yemen. All three of the Arkan Mars companies coordinated the delivery of approximately $12 million dollars’ worth of Iranian petroleum products with the Persian Gulf Petrochemical Industry Commercial Company (PGPICC) to the Houthis via Ras Isa port in Yemen. PGPICC was designated by OFAC pursuant to E.O. 13382 for being owned or controlled by Persian Gulf Petrochemical Industry Co. (PGPIC). PGPIC was itself designated pursuant to E.O. 13382 that same day for having provided financial support to Khatam al-Anbiya, the engineering conglomerate of Iran’s Islamic Revolutionary Guard Corps (IRGC). Muhammad Al-Sunaydar, Arkan Mars Petroleum Company for Oil Products Imports, Arkan Mars Petroleum DMCC, Arkan Mars Petroleum FZE, Yahya Mohammed Al Wazir, Al-Saida Stone for Trading and Agencies, and Amran Cement Factory 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, the Houthis.
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”).
