Notable "Derivative" Designations - Network of vessels and facilitators has moved hundreds of millions of dollars to Assad regime, Hizballah, and illicit actors

Date issued: Sep. 04 2019

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TURBOFAC Commentary (385 words)

Notes:

1) For the criteria we use to determine what designation notices to include in the Research System, see Introductory Note Common to all Derivative Designation Notices Included in the Research System.

2) NOTES SPECIFIC TO THIS DESIGNATION NOTICE

The designation notice is notable for the sanctioning of entities worldwide that are linked to the Mehdi Group, an Indian entity that was designated a week prior for providing material assistance to an IRGC official (Rostam Qasemi) in connection with the delivery of Iranian oil to various locations. OFAC has characterized the activities described in the designation notice as "illicit," but is not clear whether and to what extent the Mehdi Group activities are believed to violate international law, or the laws of at least one country having jurisdiction over the transactions. OFAC...