Counter Terrorism Designations; Sudan Designations; Russia-related Designation Removal; Issuance of Sudan General Licenses

The Office of Foreign Assets Control ( OFAC) has published a press release to inform about various new sanction measures. Specifically, the Office added five individuals and five entities to its Specially Designated Nationals and Blocked Persons List ( SDN List) pursuant to existing sanction regulations (31 CFR Part 594, Executive Order 13224, and Executive Order 14098) for their engagement in terrorist activities or for their contribution to the violent conflict in Sudan, respectively. The following persons and entities are affected and now subject to asset freezing measures:
#### Sanctioned Individuals
AMINI, Hossein Hafez (a.k.a. AMINI, Hosein Hafez; a.k.a. AMINI, Huseyin Hafez; a.k.a. AMINI, Hussein Hafiz; a.k.a. HAFEMAZAMINI, Huseyin; a.k.a. HAFEZAMINI, Huseyin), Turkey; DOB 23 Aug 1969; nationality Iran; alt. nationality Turkey; Gender Male; Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886; Passport A3784761 (Iran) expires 11 Aug 2021; alt. Passport U12438217 (Turkey) expires 30 Mar 2026 (individual) [SDGT] (Linked To: ISLAMIC REVOLUTIONARY GUARD CORPS (IRGC)-QODS FORCE).
ANSARI, Mohammad Reza (a.k.a. ANSARI BARKIRSAGHI, Mohammadreza; a.k.a. ANSARI, Mohammadreza; a.k.a. ANSARI, Mohammad-Reza; a.k.a. NASERI, Mostafa), Syria; DOB 22 Nov 1975; nationality Iran; Gender Male; Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886 (individual) [SDGT] (Linked To: ISLAMIC REVOLUTIONARY GUARD CORPS (IRGC)-QODS FORCE).
BAZGHANDI, Rouhollah (Arabic: روح اله بازقندی) (a.k.a. AZIMI, Ruhollah), Basement Floor 1, No. 51, 51 Sadoughi Alley, Shahid Sadoughi Boulevard, Qom, Zanbilabad District 3716945864, Iran; DOB 20 Sep 1981; POB Sabzevar, Iran; nationality Iran; Gender Male; Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886; National ID No. 0793640271 (Iran); Birth Certificate Number 4697 (Iran) (individual) [SDGT] (Linked To: ISLAMIC REVOLUTIONARY GUARD CORPS).
POURSAFI, Shahram (a.k.a. MEHDI, Rezaei; a.k.a. PORSAFI, Shahram; a.k.a. PURSAFI, Shahram; a.k.a. REZAYI, Mehdi), Syria; DOB 21 Sep 1976; POB Iran; nationality Iran; Gender Male; Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886 (individual) [SDGT] (Linked To: ISLAMIC REVOLUTIONARY GUARD CORPS (IRGC)-QODS FORCE).
SERAJ, Reza, Iran; DOB 09 Aug 1965; nationality Iran; Gender Male; Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886; Passport U50683554 (Iran) expires 18 Sep 2024; alt. Passport D10009891 (Iran) expires 28 May 2027 (individual) [SDGT] (Linked To: ISLAMIC REVOLUTIONARY GUARD CORPS).
#### Sanctioned Entities
AL JUNAID MULTI ACTIVITIES CO LTD (a.k.a. AJMAC MULTI ACTIVITIES COMPANY LTD; a.k.a. AL GUNADE; a.k.a. ALGUNADE; a.k.a. „AL JUNAID“), Street 3, Block 17, Alryad, Khartoum, Sudan; 99 Gama Avenue, P.O. Box 913, Khartoum, Sudan; Website www.ajmac.com; Organization Established Date 2009; Organization Type: Activities of holding companies [SUDAN-EO14098].
DEFENSE INDUSTRIES SYSTEM (a.k.a. MILITARY INDUSTRY CORPORATION; a.k.a. „DEFENSE INDUSTRIES CORPORATION“; a.k.a. „DEFENSE INDUSTRY SYSTEM“), Khartoum North, Khartoum 10783, Sudan; Organization Established Date 1993; Organization Type: Defense activities [SUDAN-EO14098].
REY HAVACILIK ITHALAT IHRACAT SANAYI VE TICARET ANONIM SIRKETI (a.k.a. REY AIRLINES), NO: 38-6, Cobancesme Mahallesi, Istanbul 34197, Turkey; No: 3, D: 4 K. Cekmece, Besyol Mh. Florya Is Merkezi, Istanbul, Turkey; Website www.reyairlines.com; Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886; Tax ID No. 7340772541 (Turkey); Registration Number 939568-0 (Turkey) issued 19 Sep 2014; alt. Registration Number 937110 (Turkey) issued 19 Sep 2014 [SDGT] (Linked To: AMINI, Hossein Hafez).
SUDAN MASTER TECHNOLOGY (a.k.a. GIAD INDUSTRIAL CITY; a.k.a. GIAD INDUSTRIAL GROUP), SMT Building Madani Road, KM 50 Khartoum, Giad Industrial Complex, Gamhuria Street, Khartoum, Sudan; Giad Industrial Group Building, Street 60, Giad Industrial City, PO Box 444, Khartoum, Sudan; SMT Building, Gamhuria Street, GIAD Industrial Complex, PO Box 10782, Khartoum SU001, Sudan; Website www.sudanmaster.com; Organization Established Date 01 Jan 1993; Organization Type: Activities of holding companies [SUDAN-EO14098].
TRADIVE GENERAL TRADING L.L.C (a.k.a. MOTAH GENERAL TRADING, L.L.C.), P.O. Box 86436, Dubai, United Arab Emirates; Organization Established Date 11 Nov 2018; Organization Type: Non-specialized wholesale trade; Chamber of Commerce Number 1374345 (United Arab Emirates); Business Registration Number 818826 (United Arab Emirates) [SUDAN-EO14098].
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Additionally, OFAC has published several new licenses under the newly issued E.O. 14098 to permit otherwise prohibited (financial) transactions with respect to Sudan. These licenses include
General License 1 which permits transactions for the „official conduct of business“ of the following entities:
– The International Centre for Settlement of Investment Disputes (ICSID) and the Multilateral Investment Guarantee Agency (MIGA);
– The African Development Bank Group, the Asian Development Bank, the European Bank for Reconstruction and Development, and the Inter-American Development Bank Group (IDB Group), including any fund entity administered or established by any of the foregoing;
– The International Committee of the Red Cross and the International Federation of Red Cross and Red Crescent Societies;
– The Global Fund to Fight AIDS, Tuberculosis, and Malaria, and Gavi, the Vaccine Alliance;
– The African Union, including the African Union Commission and other subsidiary bodies and organs; and
– The Intergovernmental Authority on Development (IGAD).
General License 2 which permits financial transactions in relation to nongovernmental organizations that engage in specified activities (e.g. provision of humanitarian aid, facilitation of education and democracy building, etc.).
General License 3 which permits financial transactions that are necessary for the performance of the following activities: „provision of agricultural commodities, medicine, medical devices, replacement parts and components for medical devices, or software updates for medical devices to Sudan“.
General License 4 which permits financial transactions that are „ordinarily incident and necessary to the wind down of any transaction involving Defense Industries System and Al Junaid Multi Activities Co Ltd“ or any entities owned or controlled by such (ownership interest of 50% or more). Please note the time limitation of this license.
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Furthermore, OFAC has removed one ship from its SDN List, namely
ALFA NERO (ZCTL4) Yacht 2,159GRT Cayman Islands flag; Vessel Year of Build 2007; Vessel Registration Identification IMO 1009376; MMSI 319957000 (vessel) [RUSSIA-EO14024] (Linked To: GURYEV, Andrey Grigoryevich).
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Finally, OFAC has published two accompanying statements explaining the reasoning of the above noted new designations:
1. Treasury Sanctions Military-Affiliated Companies Fueling Both Sides of the Conflict in Sudan
2. Treasury Designates Iranian Regime Operatives Involved in Assassination Plots in the United States and Abroad