200. The overall magnitude of illegal exports of charcoal from Somalia remains similar to the previous mandate, but there have been some new trends worth noting.
Al-Shabaab, in contrast to much of 2015 and 2016, when it had intermittently banned the charcoal trade in areas under its control (see S/2016/919, para. 129), has resumed the systematic taxation of charcoal at checkpoints en route to the stockpiles near the ports at Buur Gaabo and Kismayo. A conservative estimate would be that Al-Shabaab currently earns at least $10 million a year from the illicit charcoal trade.
201. Dubai, United Arab Emirates, and particularly Port Al Hamriya, continues to be the primary export destination, although there have been some attempts by charcoal traffickers to diversify to other ports in the region, including Bahrain, Kuwait and possibly Oman. The most prevalent type of false paperwork used to conceal the Somali origin of charcoal cargoes during the current mandate has been Djibouti certificates of origin. Meanwhile, transnational criminal networks, based primarily in Dubai and Kismayo, seem to be working towards a more formal structure for collaboration.
202. With the notable exceptions of the efforts made by the Combined Maritime Forces and Kuwait, implementation of the charcoal ban has been poor, particularly by the Interim Jubba Administration and the Kenyan Defence Forces contingent of AMISOM in Somalia, and the United Arab Emirates among the importing countries. A lack of commitment to consistent sanctions implementation, and in some cases a conspicuously deliberate failure to comply with the charcoal ban, enables Al-Shabaab financing and undermines counter-terrorism and counter-insurgency efforts in Somalia.
A. Production, transport and stockpiles
203. Charcoal production in Somalia, including for illicit export, has continued at a high rate. According to analysis of satellite imagery by FAO, there were approximately 26,000 total sites of charcoal production from 2011 to 2017, with approximately 4,000 sites identified during 2017.1 In 2017, the primary area of charcoal production has been south of Badhadhe, Lower Juba, in the south-east corner of Somalia, while the secondary area of charcoal production has been near Bu’ale, Middle Juba. Both have been Al-Shabaab-occupied territory.
204. The Monitoring Group has received information that, in contrast to tactics observed during the previous mandate, Al-Shabaab has resumed the systematic taxation of charcoal at checkpoints along routes from charcoal production areas to ports. The rate of taxation is $2.50 per bag of charcoal, or about $750 for a truck loaded with charcoal bags. The charcoal produced south of Badhadhe is transported by way of small roads to the Buur Gaabo stockpile, while the charcoal produced near Bu’ale would be transported along the road through Jilib and onward to the stockpiles at Kismayo.
205. The stockpiles at Kismayo and Buur Gaabo remain the main sources of exports of charcoal, while the stockpile at Barawe may also pose a threat to peace and security. On 11 and 12 June 2017, members of the Monitoring Group observed the two charcoal stockpiles located near the Port of Kismayo.
The Group also subsequently obtained photos of the third Kismayo charcoal stockpile located in the north of the city. Between 11 and 14 June, members of the Group observed the stockpiles located near the Port of Kismayo and at Buur Gaabo (see satellite imagery of the stockpiles in annex 12.1). Finally, the Group remains concerned that the charcoal stockpile at Barawe constitutes a threat to peace and security, as it could be a target for an Al-Shabaab offensive or prompt conflict among charcoal traffickers (see S/2016/919, para. 131). On 3 March 2017, in a meeting with the President of the Interim South-West Administration, the Group reiterated that the Interim South-West Administration, in consultation with the Federal Government, should seek the Committee’s guidance regarding the Barawe charcoal stockpile.2
B. Illicit export of charcoal
206. The available evidence suggests that the scale of illicit charcoal exports from Somalia has not substantially changed from the Monitoring Group’s previous mandate. The Group conservatively estimates that, other than during the monsoon season from August to October, approximately 15 dhows per month, or about 135 dhows per year, depart from Kismayo and Buur Gaabo with cargoes of charcoal.3 With cargoes averaging a volume of 30,000 bags, each weighing 25 kg, that would equal 750,000 kg of charcoal per dhow or more than 100,000 metric tons of charcoal exported per year. At an estimated value of $30 per bag wholesale in export markets (see S/2016/919, annex 9.2), approximately four million bags per year of charcoal exports would be worth $120 million.
207. The United Arab Emirates, particularly Port Al Hamriya in Dubai, continues to be the principal destination for illegal exports of charcoal from Somalia. The Monitoring Group has also received information during the current mandate regarding Somali charcoal being imported through the Port of Fujairah, United Arab Emirates, although the quantities have not yet been verified. Other Gulf Cooperation Council countries, such as Bahrain and Kuwait, have also been confirmed as destinations for Somali charcoal (see annex 12.2). The Group has also received reports regarding charcoal dhows bound for ports in Oman, but these have not been verified.
C. Paperwork and criminal networks
208. The utilization of falsified customs documentation, such as certificates of origin, continues to be the primary method for facilitating the illicit import of Somali charcoal. During the previous mandate, the main types of false charcoal paperwork were certificates of origin from the Comoros, Ghana and Pakistan (see S/2016/919, para. 138 and annex 9.7). During the current mandate, the most prevalent type of false charcoal paperwork has been Djibouti certificates of origin, with this paperwork having circulated at Port Al Hamriya in the United Arab Emirates, as well as being submitted at the Port of Doha, Kuwait. Investigations by the Monitoring Group indicate that the primary source of the false Djibouti charcoal paperwork is Basheer Khalif
Moosa, a national of Djibouti currently residing in Dubai (see annex 12.2.2). False Ghana certificates of origin have also been submitted at Port Al Hamriya and the Port of Fujairah in the United Arab Emirates during the current mandate. Other types of possibly false charcoal paperwork still under investigation by the Group include Côte d’Ivoire and United Republic of Tanzania certificates of origin. The Group has also discovered the use of falsified Sri Lankan ship registration documents by charcoal traffickers (see annex 12.2.3).
209. The patterns of the illicit charcoal trade observed by the Monitoring Group have indicated transnational criminal networks operating in Somalia and the United Arab Emirates (see S/2016/919, annex 9.6). During the current mandate, these transnational criminal networks may have assumed a more formal structure. The Group has obtained information regarding the All Star Group, also known as the All Star General Trading Company, which comprises the main illicit charcoal suppliers, traffickers and investors in Kismayo and Dubai. The Group has not been able to confirm multiple reports that the All Star Group has an exclusive agreement with the President of the Interim Jubba Administration, Ahmed Madobe, for the export of charcoal from Somalia. Likewise, the Group has not been able to confirm claims regarding a revenue sharing agreement between the All Star Group and Al-Shabaab. This would, however, be consistent with information that Ali Ahmed Naaji, a former Al-Shabaab tax collector, current All Star Group member and long-time associate of Madobe (see S/2016/919, para. 133), had received death threats from the Amniyat demanding a resumption of charcoal revenue sharing.4
D. Implementation of the charcoal ban
210. Although the Security Council reiterated in paragraph 22 of its resolution 2317 (2016) that Somali authorities should take necessary measures to prevent the export of charcoal from Somalia, in practice the Federal Government does not control the ports at either Kismayo or Buur Gaabo. The Interim Jubba Administration, which continues to be dependent on taxing illicit charcoal exports to finance its operations, has systematically failed to implement the charcoal ban since it was imposed in February 2012. AMISOM, whose Kenyan Defence Forces contingents remain deployed at the ports of Kismayo and Buur Gaabo, has neither assisted the Somali authorities in implementing the charcoal ban nor facilitated Monitoring Group access to charcoal exporting ports, as stipulated in paragraph 23 of resolution 2317 (2016). On 14 June 2017, after having arrived at Buur Gaabo by way of a United Nations helicopter from Kismayo, three members of the Group were not permitted to leave a Kenyan Defence Forces AMISOM base to inspect the nearby charcoal stockpile.5
211. The implementation of the charcoal ban by other Member States has been uneven. The United Arab Emirates, despite progress during the previous mandate, including the confiscation of several cargoes of illicit charcoal, has
regressed in terms of consistency and effectiveness (see annexes 12.2.2 and 12.2.4). Djibouti, in particular the Ambassador of Djibouti to the United Arab Emirates, Osman Moussa Darar, bears substantial responsibility for undermining the implementation of the charcoal ban through repeatedly attesting that the false certificates of origin were legal (see annex 12.2.2). Kuwait has exhibited a high standard of proactive commitment towards the ban’s implementation and has cooperated extensively with the Monitoring Group (see annex 12.2.3). Bahrain should also be noted for its cooperation with the Group, leading to the partial seizure of one cargo shipment (see annex 12.2.1).
212. The Monitoring Group would like to note cooperation by the Combined Maritime Forces, particularly Combined Task Force 152, in implementing the charcoal ban. This included the prompt sharing of information and facilitating the Group’s contact with Kuwaiti authorities during April and May, enabling the confiscation of charcoal from two dhows (see annex 12.2.3). In July and August, the Combined Maritime Forces undertook aerial reconnaissance of five dhows en route from Somalia to Port Al Hamriya anchorage that had been identified by the Group. The Combined Maritime Forces then shared dhow descriptions, location data and photos with the United Arab Emirates authorities, who have the jurisdiction to board and inspect the dhows within that country’s territorial waters. At the time of writing, the outcome remains pending (see annex 12.2.4).
Annex 12.2.1: Selected cases of sanctions implementation— Bahrain (November 2016)
1. On 22 November 2016, two members of the Monitoring Group, who were in Bahrain for meetings with Combined Maritime Forces (CMF), observed trucks departing Khalifa Bin Salman Port with cargoes of what appeared to be green bags of Somali charcoal (see figure 1). This was consistent with information received from an SEMG source that dhows had been unloading cargoes of Somali charcoal onto trucks for transhipment to Saudi Arabia (see figure 2). It also matched information communicated to the Bahrain authorities in letters from the SEMG dated 24 October 2016, 1 November 2016, and 15 November 2016 regarding the impending arrival of three dhows with a total cargo of 76,000 bags of charcoal loaded in Kismayo and another dhow with a cargo of 30,000 bags of charcoal loaded in Buur Gaabo.
2. On 23 November, two members of the SEMG met with representatives of the General Directorate of Security and Follow Up, Customs Affairs at the Ministry of Interior, Kingdom of Bahrain. The Monitoring Group shared photos taken the previous day of trucks departing Khalifa Bin Salman Port with cargoes of what appeared to be green bags of Somali charcoal. Customs Affairs agreed to provide the SEMG access to Khalifa Bin Salman Port, where a dhow, Al Hussain, claiming to be Sri Lankan-flagged with registration 91909, was unloading a cargo of 30,000 bags of suspected Somali charcoal.
3. Al Hussain had submitted paperwork claiming the port of departure had been Moroni, Comoros, while the available evidence indicated that Al Hussain was most likely an Indian-flagged dhow identified in a 15 November letter from the SEMG, Al Faizul Barkat, MNV 1967, which had loaded its cargo of 30,000 bags of charcoal from Buur Gaabo in mid-October (see figure 4).6 Customs Affairs stopped the unloading of Al Hussain and confiscated the remaining cargo of 15,000 bags of charcoal (see figure 3). Customs documentation and dockworker testimony confirmed the other three dhows previously identified by the SEMG’s letters to the Bahrain authorities had already docked and unloaded their cargo of Somali charcoal.
Annex 12.2.2: Selected cases of sanctions implementation—United Arab Emirates and Djibouti (November 2016–March 2017)
1. On 29 November 2016, the SEMG wrote to the United Arab Emirates (UAE) regarding a dhow, Naji, which had loaded 27,000 bags of charcoal in Buur Gaabo in early November, recently docked at Port Al Hamriya, and was likely to submit a false Djibouti certificate of origin. The UAE replied on 1 December 2016, noting it had partially confiscated the cargo of Naji, and providing the SEMG with a copy of a Djibouti certificate of origin (see figure 1). The Monitoring Group wrote to the UAE on 16 December 2016, stating that CMF had provided aerial photos of Naji taken near UAE territorial waters on 20 November 2016. The photos matched the description of the dhow and its cargo of distinctive green charcoal bags that had departed Buur Gaabo on 2 November and docked at Port Al Hamriya on 27 November. The SEMG also noted that the consignee, Mohd Ali Shaheen General Trading Co. (L.L.C.), had been previously identified as trafficking in illicit Somali charcoal earlier that year (see S/2016/919, annex 9.4.a).
2. The UAE replied on 5 January 2017, stating that it had received a letter from the Embassy of the Republic of Djibouti to the UAE attesting to the authenticity of Naji’s paperwork. The SEMG wrote to the UAE on 20 January, acknowledging it had received confirmation from the Djibouti Chamber of Commerce that it had issued the certificate of origin, but that the Monitoring Group remained concerned that this paperwork had been fraudulently obtained. The UAE replied on 3 February 2017, asserting that in the absence of another letter from the SEMG it would release the remaining cargo of Naji on 14 February 2017.
3. The SEMG undertook an official mission to the Republic of Djibouti from 20-24 February 2017. Following meetings with senior representatives of the Ministry of Foreign Affairs and International Cooperation, the Djibouti Ports and Free Zone Authority, Customs, and the Chamber of Commerce, the Monitoring Group confirmed that Djibouti had not exported any charcoal during 2016 and 2017 (and fewer than 3,000 bags during 2014 and 2015). The Harbour Master at the Djibouti Ports and Free Zone Authority further confirmed that no dhows with charcoal cargoes, including Naji, had arrived at or departed from Djibouti (see figure 2). On 4 November 2016, the Chamber of Commerce had issued to a local company, Abet Enterprise SARL, one certificate of origin for the export of 27,000 bags of charcoal to the UAE (as well as other certificates of origin for the export of charcoal to the Kingdom of Saudi Arabia). However, following the official mission of the Monitoring Group, the Djiboutian authorities have since concluded that these certificates were fraudulently obtained and have suspended the license of the front company, Abet Enterprise SARL (see figure 3).
4. In a letter to the UAE dated 2 March 2017, the SEMG summarized the evidence obtained during its official mission to Djibouti. The SEMG then met with the UAE authorities in Dubai on 23 March 2017, where it presented this evidence proving Djibouti certificates of origin to be false. In response to a request by the SEMG, the UAE authorities provided copies of Djibouti charcoal certificates of origin for 15 dhows that it had already accepted, with a combined cargo of 435,000 bags of charcoal weighing more than 10,000 metric tons. The Djibouti certificates of origin had been attested to by Ambassador Osman M. Darar at the Embassy of the Republic of Djibouti in Abu Dhabi between 4 November 2016 and 7 February 2017, and then submitted to UAE customs for processing. The UAE authorities agreed to cease accepting Djibouti certificates of origin on an interim basis, pending the outcome of their own investigation, including a meeting with Ambassador Darar.
5. The previous day, 22 March 2017, the Monitoring Group had met with Ambassador Darar at his office in Abu Dhabi. The SEMG presented evidence collected from Djibouti authorities during the official mission 20-24 February indicating that Djibouti had not exported any bulk cargoes of charcoal going back to at least 2014, and that the Djibouti certificates of origin from the Chamber of Commerce had been fraudulently obtained. When asked why he had attested to false paperwork, how many certificates of origin he had attested to, and who had brought him the false paperwork, Ambassador Darar directed the SEMG to address its queries through official channels. Accordingly, the Monitoring Group sent a letter to Djibouti on 28 March 2017, requesting information regarding attestation of charcoal certificates of origin by its embassy in Abu Dhabi. This included not only 435,500 bags weighing more than 10,000 metric tons from November 2016 to February 2017, but also charcoal cargoes of more than 2 million bags weighing more than 50,000 metric tons during 2014 and 2015. As of this writing, Djibouti had not replied.
6. SEMG investigations have identified Basheer Khalif Moosa, a Djiboutian national residing in Dubai, as the most likely source of the false Djibouti charcoal paperwork. Previous reporting by the Monitoring Group in 2013 and 2014 had identified Moosa as the primary source of false Djibouti paperwork for Dubai-based charcoal traffickers.7 A corporate registration document issued in 2015 by the Djibouti Office of Industrial and Commercial Property links Bashir Khalif Musse (a.k.a. Basheer Khalif Moosa) to Abet – Shir Enteprise SARL (a.k.a. Abet Enterprise SARL), the front company whose license was suspended in February 2017 by the Djibouti Ministry of Foreign Affairs and International Cooperation for fraudulently obtaining certificates of origin from the Djibouti Chamber of Commerce (see figure 4). In letters to the UAE dated 28 March and 2 June 2017, the SEMG requested an update on any investigation by the UAE authorities into the criminal network responsible for false Djibouti certificates of origin. As of this writing, the UAE had not replied to this request.
7. In the letter to the UAE dated 2 June, the SEMG also reiterated an observation it had initially made at the meeting with the UAE authorities on 23 March: the consignee for 9 out of the 15 dhows with Djibouti charcoal certificates of origin was listed as “Mohd Ali Shaheen Gen Trdg LLC”. Mohd Ali Shaheen General Trading Co. (L.L.C.) was previously identified as the consignee for a dhow possessing false Comoros paperwork, Raj Milan, whose cargo of Somali charcoal was seized and sold at public auction by the UAE authorities in 2015.8 Mohd Ali Shaheen General Trading Co. (L.L.C.) was also identified in last year’s report as the consignee for three dhows with false Comoros paperwork for cargoes of Somali charcoal, Al Zuber, Shree Nausad and Yasin.9 The cargoes of the latter two dhows were also confiscated and sold at public auction in May 2016. However, despite an evident pattern of sanctions violations, the Monitoring Group remains unaware of any investigation by the UAE authorities into Mohd Ali Shaheen General Trading Co. (L.L.C.).
Annex 12.2.3: Selected cases of sanctions implementation —Kuwait (April 2017–May 2017)
1. On 29 and 30 April 2017, the CMF contacted the Monitoring Group regarding two dhows with cargoes of charcoal that were being held by the Kuwait Coast Guard in Al Doha Port under suspicion of having violated the Somali charcoal ban. The dhows, Al Sahil and Haruni, possessed paperwork indicating that their charcoal cargo had originated in Djibouti. After reviewing the paperwork, the SEMG advised the CMF and the Kuwait Coast Guard that the certificates of origin were not authentic and that the two dhows were most likely part of a group of twelve dhows that had loaded in Buur Gaabo and Kismayo from late February to early March 2017, and had since been anchored near Port Al Hamriya. This was consistent with information that had been received from a confidential source on 25 April that two dhows with cargoes of Somali charcoal were departing Port Al Hamriya anchorage bound for Kuwait.
2. Subsequent investigation by the Monitoring Group has revealed that the dhows’ respective Sri Lankan ship registration documents had also been forged (see figure 1). During an official mission to Sri Lanka, 4-6 May, the Director General of Merchant Shipping for Sri Lanka provided evidence to the Monitoring Group indicating that the Sri Lankan ship registrations for Al Sahil and Haruni are forgeries. Al Sahil and Haruni do not appear within the official Sri Lankan ship registry, nor did their ship registration forms and accompanying stamps match originals provided by the Sri Lanka authorities.
3. The SEMG travelled to Kuwait on official mission 22-26 May. The SEMG had several meetings with the Kuwait authorities, including the coast guard and customs, inspected Al Sahil and Haruni and their cargoes of Somali charcoal, and interviewed the captains of the dhows (see figure 2). The Monitoring Group would like to acknowledge the excellent cooperation of the Kuwait authorities as well as the facilitation of information sharing by Combined Task Force 152 at CMF.
4. Interviews with the dhows’ captains indicated Al Sahilhad been loaded with 28,500 Djibouti-marked bags of charcoal in Buur Gaabo in mid-March 2017 and Harunihad been loaded with 17,350 Djibouti-marked bags of charcoal in Kismayo in early March. Both dhows proceeded to Port Al Hamriya anchorage, where they remained for several weeks until receiving false Djibouti paperwork delivered by a contact person, who also gave instructions for the dhows to proceed to Kuwait, where they arrived at Al Doha Port on 29 and 30 April. The SEMG corroborated the captains’ testimony regarding the course of each dhow through referencing the data on the dhows’ GPS devices. Upon arrival, the Kuwait authorities soon thereafter seized the dhows and their cargo and detained the crews. The loading of Djibouti-marked charcoal bags in Buur Gaabo and Kismayo (see figures 3 and 4) and the provision of false Djibouti paperwork while the dhows were anchored near Dubai suggest a vertically integrated criminal network with accomplices within both Somalia and the UAE.
5. On 13 August, at theCMF headquarters in Bahrain, a representative of the Kuwait Coast Guard updated the Monitoring Group. The charcoal cargoes of Al Sahil and Haruni have been confiscated by Customs and stored at a warehouse at the port. The dhows are in the custody of the Kuwait authorities and the captains have been charged and released on bail, pending completion of a criminal prosecution under Kuwaiti domestic law. The Monitoring Group would like to highlight the proactive stance toward sanctions implementation taken by the Kuwait authorities, setting a useful precedent for the region.
Annex 12.2.4: Selected cases of sanctions implementation —United Arab Emirates (June 2017–August 2017)
1. On 27 June 2017, the SEMG contacted the CMF regarding four dhows departing from Kismayo with a total cargo of 101,000 bags that had been loaded in Kismayo on 23 and 24 June. On 30 June, SEMG contacted the CMF regarding a fifth dhow that had loaded 40,0000 bags in Buur Gaabo on 28 June. SEMG estimated the location of the first four dhows to be on the Somalia coastline somewhere between Hobyo and Eyl, with their course set through the Strait of Socotra and onward to Port Al Hamriya. The SEMG also noted that based on a recent official mission to Kismayo and Buur Gaabo, where the charcoal stockpiles had been observed, the dhow cargoes would be comprised of typically green charcoal bags. The CMF was also informed that should there be an opportunity for maritime interdiction, the dhows may possess a false ship registration but likely no paperwork regarding their illicit cargo, as this would be received from charcoal traffickers at Port Al Hamriya anchorage. On 1 July, the CMF informed the SEMG that “contacts of interest” matching the description of the dhows with charcoal cargoes had been identified and were being tracked.
2. On 6 July, the Monitoring Group wrote to the UAE regarding the impending arrival of five dhows with a total cargo of 141,000 bags of charcoal from Somalia. The SEMG noted that checkpoint taxation in Somalia by Al-Shabaab at a rate of $2.50 per bag likely generated at least $350,000 in income for the armed group. The UAE was informed that the CMF was tracking the five dhows and their anticipated destination was Port Al Hamriya anchorage. The letter further explained that the names and registrations of the dhows would be altered, so the best way to identify them would be through reference to the size of their cargo and the type of charcoal bags coming from Kismayo and Buur Gaabo — a distinctive green colour with possible markings of “Bay and Bakool” or the image of a palm tree (see figure 1). The Monitoring Group also noted that the dhows may attempt to dock with false Côte d’Ivoire paperwork and requested copies of all Côte d’Ivoire certificates of origin submitted since April 2017 — when the UAE stopped taking false Djibouti certificates of origin.
3. The CMF subsequently located at Port Al Hamriya anchorage — within the territorial waters of the UAE — the five dhows it had tracked en route from Somalia, through the Strait of Socotra, and along the Yemen and Oman coastlines (see annex 12.2.5, strictly confidential). On more than a dozen distinct occasions between 14 July and 22 August, detailed information was communicated from the CMF to the UAE authorities regarding these dhows in anticipation that they would take sanctions enforcement action.10 The lines of communication to the UAE authorities included via the US Naval Forces Central Command (NAVCENT), the US Naval Criminal Investigative Service (NCIS), and the US Defence Attaché to the UAE. The UAE authorities that were regularly notified regarding these dhows included the UAE Coast Guard, UAE Navy, UAE Federal Customs Authority, and the Dubai Police. Initially, the information shared included descriptions of the dhows and their cargoes, plus their precise geographic locations; subsequently, this was expanded to sharing more detailed reports, including imagery and analysis.
4. Meanwhile, events at Port Al Hamriya anchorage seemed to indicate that the charcoal traffickers had become aware that the UAE authorities had been notified and that the CMF was tracking the dhows, as had been indicated in the SEMG’s confidential letter dated 6 July. On 6 August, the UAE replied to the SEMG’s letter of 6 July, stating the relevant customs authorities had been informed and requesting the registrations of the five dhows, despite the Monitoring Group already having indicated that the charcoal traffickers would utilize fake names and registrations for the dhows. That same day, the CMF aerial surveillance documented dhows which had been tracked from near the Somalia coastline transferring their cargo of charcoal onto other dhows while anchored within UAE territorial waters(see annex 12.2.5, strictly confidential). Despite having received detailed real-time information from the CMF on more than a dozen occasions, the UAE Coast Guard, which had the jurisdiction to take enforcement action, failed to board and inspect the dhows at Port Al Hamriya anchorage.
5. On 25 August 2017, the UAE wrote to the Monitoring Group regarding two dhows, Maha (registration SL301240) and Ola (registration 9330112), suspected of violating the Somali charcoal ban. Their respective cargoes consisted of 10,320 bags and 26,470 bags. The UAE provided copies of Ghana certificates of origin, invoices, packing lists, and supporting documents from Ghana authorities in Accra and at the Ghana Consulate General in Dubai (see figure 2). On 29 August, the Monitoring Group replied to the UAE, noting the following points:
the shipping company identified on the paperwork, “Sea Shore Marine Services Limited”, is not listed on the registry of licensed charcoal exporters from Ghana;
· the consignee, Salim Al Khattal Group Marine Contracting & Trading LLC, has previously traded in illicit Somali charcoal using false Ghana paperwork (see S/2016/919, annex 9.4.b);
· the stamp of the notary public which appears on the certificates of origin and legal declarations is the same stamp previously used on false Ghana paperwork during 2016 (S/2016/919, annex 9.7.c); and
· the SEMG believes that the charcoal aboard Maha and Ola was transported to Port Al Hamriya anchorage aboard one of the dhows identified in its letter of 6 July before being transferred to these dhows in an attempt at sanctions evasion.
6. The Monitoring Group recommended that the cargoes of Maha and Ola not be released to the consignee and that the UAE authorities consider confiscation of the total cargo of 36,790 bags of charcoal. At the time of writing, a reply from the UAE remains pending.
Somali environmental group
based in Nairobi/Kenya