Tanker operator faces US treasury sanctions for illicit transfers of oil to Iran

The US Department of the Treasury’s Office of Foreign Assets Control (OFAC) is taking additional action against Iranian military revenue generation, targeting shipping company Oceanlink Maritime DMCC for facilitating the shipment of Iranian commodities on behalf of Iran’s Armed Forces General Staff (AFGS) and Ministry of Defence and Armed Forces Logistics (MODAFL).

OFAC is also identifying 13 vessels managed by Oceanlink Maritime DMCC as blocked property.

The Oceanlink Maritime DMCC-managed vessel Hecate recently loaded Iranian commodities valued at over US$100 million via a ship-to-ship (STS) transfer from another sanctioned tanker on behalf of Iran’s Sepehr Energy Jahan Nama Pars (Sepehr Energy), which OFAC sanctioned in November 2023 for its role selling Iranian commodities for the AFGS and MODAFL.

OFAC is also updating the Specially Designated Nationals and Blocked Persons List (SDN List) to reflect that the name of OFAC-sanctioned vessel Young Yong has been changed to Saint Light, possibly to obfuscate its identity.

Saint Light, which is also operating under the name Stellar Oracle, conducted an STS transfer on March 27, 2024 with a sanctioned vessel operated by the National Iranian Tanker Company (NITC), from which it loaded over US$100 million worth of Iranian commodities.

Hawk, the vessel from which the transfer originated, had loaded the same cargo on March 22, 2024 via an STS transfer from the vessel Kohana, which OFAC sanctioned on February 27, 2024 for its role in attempting to ship MODAFL-owned commodities.

The recent OFAC action is being taken pursuant to the counterterrorism authority in Executive Order (EO) 13224, as amended. OFAC designated Sepehr Energy pursuant to EO 13224, as amended, on November 29, 2023, for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of MODAFL.

OFAC designated MODAFL pursuant to EO 13224 on March 26, 2019 for providing material support to Iran’s Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF).

MODAFL’s illicit commercial activity

The Treasury Department said Oceanlink Maritime DMCC operates a fleet of over one dozen vessels that are “deeply involved” in the shipment of Iranian commodities, including on behalf of Iran’s military. On March 25, 2024, Dover, a vessel operated by NITC and carrying over US$100 million worth of commodities on behalf of Sepehr Energy, conducted an STS transfer with the Comoros-flagged, Oceanlink Maritime DMCC-managed Hecate, using obfuscation techniques to conceal the locations of the vessels.

Sepehr Energy has also shipped Iranian commodities using the Comoros-flagged Anthea and Boreas, both of which are managed by Oceanlink Maritime DMCC.

Oceanlink Maritime DMCC also manages other ships registered under the flags of Comoros (four), Antigua and Barbuda (two), Belize (two), Panama (one), and the Cook Islands (one). These vessels have all shipped Iranian commodities, some as recently as March of this year.

Oceanlink Maritime DMCC, which is based in the UAE, is being designated pursuant to EO 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, Sepehr Energy. The sanctioned tankers are being identified as property in which Oceanlink Maritime has an interest.

Sanctions implications

As a result of the OFAC action, all property and interests in property of the designated persons described above that are in the United States or in the possession or control of US persons are blocked and must be reported to OFAC. In addition, any entities that are owned, directly or indirectly, individually or in the aggregate, 50 percent or more by one or more blocked persons are also blocked.

Unless authorised by a general or specific license issued by OFAC, or exempt, OFAC’s regulations generally prohibit all transactions by US persons or within (or transiting) the United States that involve any property or interests in property of designated or otherwise blocked persons.

In addition, financial institutions and other persons that engage in certain transactions or activities with the sanctioned entities and individuals may expose themselves to sanctions or be subject to an enforcement action. The prohibitions include the making of any contribution or provision of funds, goods, or services by, to, or for the benefit of any designated person, or the receipt of any contribution or provision of funds, goods, or services from any such person.