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Treasury Sanctions Houthi Weapons Smuggling and Procurement Networks

LMH editor ~ 10/27/2024
October 2 , 2024 Targets Houthi Procurement Operatives and Suppliers in Iran and ChinaWASHINGTON — Today , the U.S. Department of the Treasury ’ s Office of Foreign Assets Control ( OFAC ) is designating one individual and three companies that have facilitated weapons procurement and smuggling operations for Ansarallah

Targets Houthi Procurement Operatives and Suppliers in Iran and China

WASHINGTON — Today, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) is designating one individual and three companies that have facilitated weapons procurement and smuggling operations for Ansarallah, commonly known as the Houthis. This action targets key procurement operatives and suppliers located in Iran and the People’s Republic of China (PRC) that have enabled the Houthis to acquire dual-use materials and components needed to manufacture, maintain, and deploy an arsenal of advanced missiles and unmanned aerial vehicles (UAVs) against U.S. and allied interests.

Additionally, OFAC is sanctioning one entity and two vessels linked with illicit Houthi and Iranian commercial shipments, including one that has transported shipments for Houthi financial official Sa’id al-Jamal and an affiliate of Iran’s Armed Forces General Staff. 

“The Houthis continue to leverage their networks of companies and procurement operatives to sustain their reckless attacks on civilian vessels, their unarmed crews, and civilian populations,” said Acting Under Secretary of the Treasury for Terrorism and Financial Intelligence Bradley T. Smith. “Treasury remains committed to using our full suite of tools to disrupt the supply chain networks that enable the Houthis’ destabilizing activities.”

Today’s action is being taken pursuant to the counterterrorism authority Executive Order (E.O.) 13224, as amended, and builds on OFAC’s June 17, 2024 and July 31, 2024 actions targeting Houthi weapons procurement operatives and suppliers based in Yemen, the PRC, Hong Kong, and Oman. The U.S. Department of State designated Ansarallah as a Specially Designated Global Terrorist pursuant to E.O. 13224, as amended, effective February 16, 2024, for having committed or attempted to commit, posing a significant risk of committing, or having participated in training to commit acts of terrorism. 

HOUTHI-LINKED SHIPPING FACILITATOR

The Houthis use a network of international shipping and logistics companies to transport military-grade components from third-country suppliers to their forces in Yemen. Shenzhen Boyu Imports and Exports Co., Limited (Shenzhen Boyu) is a PRC-based logistics and international shipping firm that has facilitated multiple shipments of dual-use components for use in weapons production to Houthi militants. Houthi logistics operatives have used Shenzhen Boyu to transport these important dual-use and military grade items via commercial methods in an effort to evade interdiction. 

Shenzhen Boyu 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, Ansarallah.

PRC-BASED SUPPLIERS FOR HOUTHI WEAPONS PROCUREMENT

Houthi procurement operatives continue to source dual-use components and other military-grade items from a range of PRC-based companies. The Houthis have procured tens of thousands of dollars’ worth of dual-use components from PRC-based Shenzhen Jinghon Electronics Limited (Shenzhen Jinghon), which Houthi forces have used to advance their domestic missile and UAV production efforts. 

PRC-based technology firm Shenzhen Rion Technology Co., Ltd. (Shenzhen Rion) is another entity from which the Houthis have sourced critical components for use in missiles and UAV development and manufacturing. Shenzhen Rion has shipped numerous military-grade components to Houthi operatives in Yemen, including hundreds of advanced components for use in the manufacturing of missile guidance systems. Shenzhen Rion was previously designated pursuant to the counterproliferation authority E.O. 13382 on July 30, 2024 for having provided, or attempted to provide, financial, material, technological or other support for, or goods or services in support of, Iran’s Ministry of Defense and Armed Forces Logistics.

 Shenzhen Jinghon and Shenzhen Rion 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, Ansarallah.

HOUTHI SMUGGLING OPERATIVE

Houthi operatives located in Iran and elsewhere manage an array of supply chains and smuggling networks to transport dual-use materials and other lethal aid into Houthi-controlled territory. Iran-based Hasan Ahmad Hasan Muhammad al-Kuhlani (Hasan Al-Kuhlani) has facilitated Houthi weapons smuggling efforts. Hasan Al-Kuhlani has also coordinated to conceal and transport Iranian lethal aid to Houthi forces. 

Hasan Al-Kuhlani is being designated pursuant to E.O. 13224, as amended, for having acted or purported to act for or on behalf of, directly or indirectly, Ansarallah. 

OIL SHIPMENTS SUPPORTING IRANIAN PARTNER AND PROXY DESTABILIZING ACTIVITIES

The Gabon-flagged IZUMO (IMO: 9249324) is currently transporting petroleum products on behalf of sanctioned Iranian Armed Forces General Staff (AFGS) front company Sepehr Energy Jahan Nama Pars Company (Sepehr Energy). The IZUMO has also transported petroleum products for the network of sanctioned Houthi financial official Sa’id al-Jamal.  Sa’id al-Jamal's network has provided tens of millions of dollars of illicit oil sales revenue to support the funding of the Houthis’ attacks against commercial shipping in the Red Sea. 

The IZUMO is owned, managed, and operated by the Marshall Islands-registered Gemini Marine Limited. Gemini Marine Limited additionally owns the Cook Islands-flagged crude oil tanker FRUNZE (IMO: 9263643). The FRUNZE has also been linked to the transport of illicit Iranian oil and both vessels have been associated with illicit Russian oil shipments. 

Gemini Marine Limited 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 Jahan Nama Pars Company. The IZUMO and FRUNZE are being identified as property in which Gemini Marine Limited has an interest.   

SANCTIONS IMPLICATIONS

As a result of today’s action, all property and interests in property of the individuals named above, and of any entities that are owned, directly or indirectly, 50 percent or more by them, individually, or with other blocked persons, that are in the United States or in the possession or control of U.S. persons must be blocked and reported to OFAC. OFAC’s regulations generally prohibit all dealings by U.S. persons or within the United States (including transactions transiting the United States) that involve any property or interests in property of designated or blocked persons. U.S. persons must comply with OFAC regulations, including all U.S. citizens and permanent resident aliens regardless of where they are located, all persons within the United States, and all U.S.-incorporated entities and their foreign branches. Non-U.S. persons are also subject to certain OFAC prohibitions. For example, non-U.S. persons are prohibited from causing or conspiring to cause U.S. persons to wittingly or unwittingly violate U.S. sanctions, as well as engaging in conduct that evades U.S. sanctions. Violations of OFAC regulations may result in civil or criminal penalties. OFAC may impose civil penalties for sanctions violations based on strict liability, meaning that a person subject to U.S. jurisdiction may be held civilly liable even if such person did not know or have reason to know that it was engaging in a transaction that was prohibited under sanctions laws and regulations administered by OFAC. OFAC’s Economic Sanctions Enforcement Guidelines provide more information regarding OFAC’s enforcement of U.S. economic sanctions, including the factors that OFAC generally considers when determining an appropriate response to an apparent violation. For additional information on complying with U.S. sanctions and export control laws, please see Department of Commerce, Department of the Treasury, and Department of Justice Tri-Seal Compliance Note.

Furthermore, engaging in certain transactions with the individuals designated today entails risk of secondary sanctions pursuant to E.O. 13224, as amended. Pursuant to this authority, OFAC can prohibit or impose strict conditions on the opening or maintaining in the United States of a correspondent account or a payable-through account of any foreign financial institution that knowingly conducted or facilitated any significant transaction on behalf of a Specially Designated Global Terrorist. 

The power and integrity of OFAC sanctions derive not only from OFAC’s ability to designate and add persons to the SDN List, but also from its willingness to remove persons from the SDN List consistent with the law. The ultimate goal of sanctions is not to punish, but to bring about a positive change in behavior. For information concerning the process for seeking removal from an OFAC list, including the SDN List, please refer to OFAC’s Frequently Asked Question 897 hereFor detailed information on the process to submit a request for removal from an OFAC sanctions list, please click here.

Click here for more information on the individual and entities identified today.

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