Using public records, we found multiple active companies linked to this network in the Middle East, Europe, and Latin America. These general trading and shipping companies, which remain unsanctioned, pose a risk to individuals or companies that might unknowingly do business with them, as they could be potential conduits for terror financing based on their connections to known terror financiers. Sayari has previously investigated an Iranian oil smuggling scheme that involved an offshore jurisdiction mentioned in this investigation.
What is the IRGC-QF and who are the Houthis?
Iran’s IRGC-QF is subordinate to the IRGC, a branch of the Iranian Armed Forces, and is tasked with foreign operations. The U.S. government sanctioned both entities in 2007 for their destabilizing activities in the Middle East and military support to other groups that threaten U.S. interests in the region, in particular Hezbollah in Lebanon, the Syrian government, and the Houthis in Yemen.
The Houthis come from a community of Zaydi Shia Muslims in northern Yemen. The Zaydis comprise roughly 40 percent of Yemen’s majority Sunni population. In the 1990s and 2000s, the Houthis became a solidified, armed opposition group that succeeded in repelling offensives launched by the former president of Yemen, Ali Abdullah Salah, before later siding with him in opposition to the current government led by Abdrabbuh Mansur Hadi.
In January 2021, the Trump administration sanctioned the Houthis outright due to their human rights abuses and actions against U.S. interests in the region, in particular cross-border attacks into Saudi Arabia, but the Biden administration reversed the decision the following month because of the humanitarian implications.
The violent conflict in Yemen began in 2014 with a Houthi-led armed revolution that evolved into a protracted civil war involving multiple internal and external actors. The conflict has led to the largest humanitarian crisis in the world with millions facing starvation and displacement. International aid organizations rely on Houthi infrastructure to distribute humanitarian aid as they control Yemen’s capital and the country’s northern region, where most of Yemen’s population lives.
Panamanian and Turkish shipping companies: possible conduits for terror financing?
Iran-based Yemeni national Sa’id Jamal heads a network that generates tens of millions of dollars from the smuggling of Iranian petroleum and petroleum-based commodities, which helps finance Iran’s IRGC-QF, according to OFAC. Jamal also funnels proceeds from this illicit petrochemical smuggling to the Houthis in Yemen by way of intermediaries and exchange houses.
We found two of Jamal’s accomplices named by OFAC in public records — Abdi Naser Ali Mahamud and Abdul Jalil Mallah. They are linked to unsanctioned companies in Panama, Turkey, Sweden, and possibly Greece. OFAC sanctioned other Turkish companies at the same time it sanctioned Jamal, Mahamud, and Mallah.
Mahamud, a Turkey-based UK national, acts as a financial intermediary for Jamal, according to OFAC. Mallah, a Greece-based Syrian national, has facilitated transactions worth millions of dollars at the order of Jamal to Houthi-affiliated exchange houses in Yemen, and has used his shipping company to send Iranian petrochemicals to Syria and Hezbollah in Lebanon.
Istanbul’s Chamber of Commerce lists Mahamud as the sole board member of Turkey-based JJO GENERAL TRADİNG GIDA SANAYİ VE TİCARET ANONİM ŞİRKETİ. The company has a general trading license that specifies the ability to ship internationally anything related to foodstuffs. Although petrochemicals are not named, OFAC also sanctioned multiple general trading companies, including in the UAE and Turkey, that are a part of this network.
The necessity of shipping networks to smuggle petrochemicals makes salient some of the unsanctioned shipping companies in this network.
Mallah is the 100 percent shareholder of Turkey-based NAVIGATOR DENİZCİLİK LİMİTED ŞİRKETİ. The company was registered in October 2018 and its business license allows for the international and domestic transportation of all goods, including: passengers, fuel, mineral oil and water, according to Turkish public records
Panamanian records list Mallah and Luay as directors of ORYX MARITIME S.A. and Mallah and another possible brother, Ali, on another Panama-based shipping company – MADISON LINE SHIPPING S.A. These companies can engage in the administration of ship purchasing, selling, chartering, and the general operation of shipping agencies, according to records from Panama’s commercial register.