March 2024 Iran Tanker Tracking

Just as travelers may not generally enter other countries without a valid passport, ships may not dock at foreign ports without a recognized flag. So it was a significant step this month when the U.S. State Department—for the first time—publicly called on Panama, until last year the largest flag-provider in the world, to strip its flag from vessels carrying Iranian oil. The Panama Maritime Administration (AMP) has repeatedly come under fire for allegedly facilitating Iran’s evasion of sanctions through its “flags of convenience” system. This arrangement allows ship owners to register vessels in Panama, granting anonymity and minimal oversight in exchange for a fee.

As Deputy Special Envoy to Iran, Abram Paley, stated, “Our aim is to prevent ships from supporting groups designated as Iranian terrorist organizations through illegal oil sales." Paley’s statements in Panama underscore the abuse of the country’s flag registry by Iran and its affiliates to bypass sanctions.  As UANI has been highlighting for more than three years—including in a January 2023 Washington Post op-ed by UANI advisory board member Jeb Bush—the AMP is reliably the worst offender for this particular practice. Indeed, the AMP continues to flag almost half of all the tankers in our “Ghost Armada.”

Based on their performance since September 2020, when UANI first wrote the AMP, it is likely the Panamanians will continue to refrain from taking concrete steps to address concerns that are now shared by more than one-fifth of all U.S. Senators, including Sens. Rubio (R) and Casey (D). The AMP’s consistent message—whether to UANI, Democratic and Republican Senators, or former Presidential candidates—boils down to a simple message: “We reject any involvement of the Republic of Panama in activities that facilitate non-compliance.”

As a corollary of Panama’s multi-year reluctance to simply remove its flag from dozens of tankers, the Islamic Republic’s task of engaging ships to carry its oil has proven so much easier. At what point Panama will give up its intransigence, if ever, is hard to gauge, but we nonetheless welcome the Deputy Special Envoy’s recent efforts.

*Figures to be updated over the following weeks

While the case of Panama and its feigned ignorance of Iran-owned ships using its flag illustrates the challenges in curbing evasion practices, it is crucial to recognize that this issue extends beyond any single nation's jurisdiction or regulatory framework.

The U.S. government's recent designation of entities, including Cap Tees Shipping Co. Ltd and Cielo Maritime Ltd., marks a commendable effort to tackle the networks facilitating sanction evasion. Yet targeting individual companies is still not enough. Shared addresses linking other front and shell companies and mutual operational details across sanctioned and yet-to-be-sanctioned entities show the incredible complexity of evasion tactics. A better approach should account for the full spectrum of entities involved in the same network—not just isolated actors.

For example, an address—Room 06, 17th Floor, Wellborne Commercial 8 Java Road, Hong Kong—emerges as a central hub for various entities, linking to the sanctioned entities such as Cap Tees Shipping Co. Ltd and Cielo Maritime Ltd. Among the entities also operating from this address is Stellar Ocean Ltd, which is connected to the vessel RIQUEZA (IMO: 9233650), plus Rai Run Da Shipping Ltd-managed NIERUS (IMO: 9234666) and Townsend Shipping Ltd-affiliated BELLA 1 (IMO: 9230880).  The shared address is not coincidental. These same vessels are known carriers of Iranian oil on UANI’s "Ghost Armada" list.

Another example is Melody Ship Management, designated on March 24, 2024. This entity shares an address with Carlis Shipmanagement Pvt Ltd (Carlis) at Office 309, 3rd Floor, Space 912, ABV Brand Factory, Mira Bhayandar Road, Mira Road (E), Thane, Maharashtra, 401107, India.  Carlis is recognized as the former manager of SARAK (IMO: 9226968), MASAL (IMO: 9169421), and SOBAR (IMO: 9221970)—three Iranian-flagged vessels, two under sanctions.

Thus, sanctions enforcement must go beyond targeting individual entities and address the entire network. By focusing on isolated actors without acknowledging their multiple connections, the true potential of sanctions as a tool for international policy enforcement is not fully realized. A more encompassing strategy that targets the whole interconnected spectrum is crucial.