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6/11/2021

Treasury Sanctions Network Financing Houthi Aggression and Instability in Yemen | U.S. Department of the Treasury

U.S. DEPARTMENT OF THE TREASURY
Treasury Sanctions Network Financing Houthi Aggression and
Instability in Yemen
June 10, 2021

WASHINGTON — Today, the U.S. Department of the Treasury’s O ice of Foreign Assets
Control (OFAC) is designating members of a smuggling network that helps fund Iran’s Islamic
Revolutionary Guard Corps-Qods Force (IRGC-QF) and the Houthis in Yemen. Led by Iranbased Houthi financier Sa’id al-Jamal, this network generates tens of millions of dollars in
revenue from the sale of commodities, like Iranian petroleum, a significant portion of which
is then directed through a complex network of intermediaries and exchange houses in
multiple countries to the Houthis in Yemen.
“This network’s financial support enables the Houthis’ deplorable attacks threatening
civilian and critical infrastructure in Yemen and Saudi Arabia. These attacks undermine
e orts to bring the conflict to an end and, most tragically, starve tens of millions of innocent
civilians,” said Director of the O ice of Foreign Assets Control Andrea M. Gacki. “Ending the
su ering of millions of Yemenis is of paramount concern to the United States, and we will
continue to hold accountable those responsible for widespread misery and deny them
access to the global financial system.”
Today’s action is being taken pursuant to the counterterrorism authority Executive Order
(E.O.) 13224, as amended. The IRGC-QF was designated pursuant to E.O. 13224 in 2007 for
support to numerous terrorist groups.
Since the onset of the conflict in Yemen, the Houthis have relied on support from the IRGCQF to wage their campaign against the internationally recognized Yemeni government and
the Saudi-led Coalition. Despite growing calls for peace, the Houthis have continued to
escalate their lethal attacks inside Yemen and in the region, with dire consequences for
Yemeni civilians and Yemen’s neighbors. The Houthis have used ballistic missiles,
explosives, naval mines, and Unmanned Aerial Vehicles to strike military targets, population
centers, infrastructure, and nearby commercial shipping in Saudi Arabia, along key
international trade routes.

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Treasury Sanctions Network Financing Houthi Aggression and Instability in Yemen | U.S. Department of the Treasury

Today, OFAC and the Department of State are also li ing sanctions on three former
Government of Iran o icials, and two companies formerly involved in the purchase,
acquisition, sale, transport, or marketing of Iranian petrochemical products. These delistings
are a result of a verified change in behavior or status on the part of the sanctioned parties
and demonstrate the U.S. government’s commitment to li ing sanctions in the event of a
change in behavior or status for sanctioned persons.

SA’ID AL-JAMAL: F INANCIAL CONDUIT TO THE HOUTHIS
Sa’id al-Jamal, an Iran-based Houthi financial supporter, directs a network of front
companies and vessels that smuggle Iranian fuel, petroleum products, and other
commodities to customers throughout the Middle East, Africa, and Asia. A significant portion
of the revenue generated from these sales is directed through a complex international
network of intermediaries and exchange houses to the Houthis in Yemen. This revenue
helps fund the destabilizing regional activities of the Houthis, IRGC-QF, and others, including
Hizballah. Sa’id al-Jamal’s network has generated tens of millions of dollars in revenue
through the sale of Iranian commodities to those willing to evade sanctions. Sa’id al-Jamal
also maintains connections to Hizballah and has worked with the group to send millions of
dollars to support the Houthis.
Sa’id al-Jamal 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, the IRGC-QF.
OFAC is also identifying the Gabon-flagged vessel Triple Success, which has been used by
Sa’id al-Jamal to smuggle Iranian petroleum products out of Iran, as property in which Sa’id
al-Jamal has an interest.

SA’ID AL-JAMAL’S INTERNATIONAL SUPPORT NETW ORK
A cohort of businessmen and shipping experts support Sa’id al-Jamal’s network, enabling
the illicit sale of Iranian goods abroad and the repatriation of profits to entities including the
Houthis in Yemen, and the IRGC-QF.
Turkey-based Houthi-a iliate Abdi Nasir Ali Mahamud, a key business partner of Sa’id alJamal, acts as a financial intermediary and has coordinated the smuggling of petrochemicals
for the network. Mahamud has leveraged his position as managing director of UAE-based
Adoon General Trading FZE to facilitate the transfer of millions of dollars on behalf of Sa’id
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Treasury Sanctions Network Financing Houthi Aggression and Instability in Yemen | U.S. Department of the Treasury

al-Jamal. Mahamud 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, Sa’id al-Jamal.
Adoon General Trading FZE and two additional companies, UAE-based Adoon General
Trading L.L.C. and Turkey-based Adoon General Trading Gida Sanayi Ve Ticaret Anonim
Sirketi, are being designated pursuant to E.O. 13224, as amended, for being owned,
controlled, or directed by, directly or indirectly, Mahamud.
UAE-based Indian national Manoj Sabharwal is a maritime shipping professional who
manages shipping operations for Sa’id al-Jamal’s network and advises al-Jamal on
smuggling Iranian oil products. Sabharwal is responsible for coordinating shipments of
Iranian petroleum products and commodities throughout the Middle East and Asia while
obscuring Sa’id al-Jamal’s involvement. Sabharwal 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, Sa’id al-Jamal.
Hani ‘Abd-al-Majid Muhammad As’ad, a Turkey-based Yemeni accountant a iliated with the
Houthis, manages Sa’id al-Jamal's finances and has used multiple bank accounts to send
and receive millions of dollars in payments for Sa’id al-Jamal’s shipping operations, as well
as to facilitate transfers to the Houthis in Yemen. As’ad 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, Sa’id al-Jamal.
Since 2017, Jami’ ‘Ali Muhammad, a Somali businessman and Houthi and IRGC-QF
associate, has assisted Sa’id al-Jamal’s e orts to procure vessels, facilitate shipments of
Iranian fuel, and transfer funds for the benefit of the Houthis. Jami’ 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, Sa’id
al-Jamal.
At the direction of Sa’id al-Jamal, Turkey-based Syrian national Talib ‘Ali Husayn Al-Ahmad
al-Rawi and Greece-based Syrian national Abdul Jalil Mallah have facilitated transactions
worth millions of dollars to Swaid and Sons, a Yemen-based exchange house associated
with the Houthis. Sa’id al-Jamal has used Swaid and Sons to send millions of dollars to
IRGC-QF o icials deployed in Yemen.

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Mallah has facilitated the shipment of Iranian crude oil to Syria. Mallah has worked with
Sa’id al-Jamal to send millions of dollars’ worth of Iranian crude oil to Hizballah. Al-Rawi
has worked with Sa’id al-Jamal to transfer millions of dollars from Qatirji Group purchases of
Iranian petroleum products to Swaid and Sons in Yemen. Al-Rawi, Mallah, and Swaid and
Sons 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.

SANCTIONS IMPLICATIONS
All property and interests in property subject to U.S. jurisdiction of the persons designated
are blocked, and U.S. persons are generally prohibited from engaging in transactions with
the designated persons or their blocked property. In addition, foreign financial institutions
that knowingly facilitate significant transactions for, or persons that provide material or
certain other support to, the persons designated today risk exposure to sanctions that could
sever their access to the U.S. financial system or block their property or interests in property
under U.S. jurisdiction.
View identifying information on the individuals and entities designated today.
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