In Bangladesh, Brazil and Bulgaria: Iran’s Sanctioned Fleet Continues Circling the Globe

When the second big round of Iran sanctions was reimposed in November last year, the U.S. added 199 Iranian vessels to its Specially Designated Nationals (SDN) list.  Despite this, Iran’s sanctioned fleet of container ships, bulk carriers and general cargo vessels continue to call at ports all around the globe – from Bulgaria to Brazil.

While most Iran watchers are focused on Iranian oil tankers delivering crude oil to China, the American campaign of “maximum pressure” can only succeed if attention encompasses all instances of sanctioned Iranian vessels unloading around the world. Regardless of what these ships are carrying, this phenomenon should be a cause for concern because all Iranian exports ultimately help the regime finance its illicit proliferation programs and bankroll terrorist proxies.

To be clear, even non-U.S. port operators, port authorities, vessel agents, and other maritime services companies that provide any service to vessels that are now included on OFAC’s SDN list are exposed to the imposition of secondary sanctions by the U.S. Government. As the U.S. law firm Reed Smith stated in a legal advisory in May 2018, “To avoid incurring negative attention from OFAC… no services should be provided in support of Iran-related shipping business from November 5, 2018.”

Yet, despite the risk of exposure to secondary sanctions, port operators and controlling authorities continue to allow Iran’s bulk carriers, general cargo and container vessels to make dozens of calls to ports in China, India, Iraq, Russia, Vietnam Singapore and Turkey. Maybe it is not surprising to see evidence of Iranian ships making stops in these countries, given their stated willingness to develop or sustain ties with the Islamic Republic of Iran, even in the face of tough U.S. sanctions. It is surprising, however, to witness Iranian vessels in countries including Bangladesh, Bulgaria, Brazil, Kenya, Indonesia, Malaysia, Romania, Slovenia, Sri Lanka, Syria, Taiwan, Tanzania, Thailand, and Ukraine, countries that historically have done little to no trade with Iran. Several are even counted as U.S. allies.

More surprising still is that even some European countries including Italy, Belgium and Bulgaria continue to allow SDN-listed vessels to call at their ports. In 2016, the Port of Antwerp signed a collaboration agreement with Iran’s Shahid Rajaee Port Authority “to help companies in both ports to collaborate and develop trade between the two regions.”  Since the reimposition of sanctions, three of Iran’s sanctioned container vessels have called at Belgium’s Antwerp Gateway Terminal on multiple occasions. One of those, the AZARGOUN, has visited Antwerp five times since November 5, 2018 and has historically transported Iranian petrochemicals – now a sanctioned product – to Belgium’s biggest port.

The same vessels, AZARGOUN, ARTABAZ, and GOLBON, have also visited and continue to call at the key Mediterranean ports of Valencia in Spain and Genoa in Italy – to where AZARGOUN is currently heading.  The Genoese nexus recently hit the headlines with the November 2018 seizure of 595lb of heroin on board ARTABAZ, which came from Bandar Abbas, Iran’s largest container port. And in April this year, after departing Bulgaria’s Black Sea port of Burgas en-route to Misrata in Libya, the Libyan Government of National Accord (GNA) detained the SHAHR E KORD, another Iranian sanctioned vessel, and discovered a cache of weapons boxed in 144 containers aboard.

While we should commend the Libyan and Italian authorities for their decisive actions against ships carrying drugs and weapons, the overriding issue of sanctioned Iranian ships transiting ports around the world demonstrates that more needs to be done. While the current focus may well be stopping crude, at some stage U.S. authorities must turn their attention to all those port operators, owners and maritime authorities that allowed SDN ships to dock. Port records are publicly accessible and indelibly recorded. Ultimately, the shipping community would be wise to make explicit their commitments to denying any further docking privileges to all sanctioned vessels and vessels belonging to sanctioned entities, sooner rather than later.

Claire Jungman is the Chief of Staff at United Against Nuclear Iran (UANI) in New York. She provides direct support to UANI’s senior leadership and staff.  Daniel Roth is Director of Research at United Against Nuclear Iran (UANI) in New York. He leads UANI’s business intelligence and corporate engagement efforts.