November 2024 Iran Tanker Tracker

The incoming second Trump Administration has reignited interest in the "Maximum Pressure" campaign on Iran, signaling intentions to further limit the Iranian regime’s oil exports and its financial resources. While these actions aim to curb Iran’s destabilizing influence, the persistence and expansion of illicit networks—operating under the guise of the "Dark Fleet"—underscore the ongoing challenges to enforcement.

Despite a growing list of sanctions over the past year, these clandestine networks of traders and their aging tankers have persisted and grown in size and operational prominence. The increasing reliance on aging vessels, many of which would have otherwise been decommissioned, highlights a troubling trend. Observations in 2024 indicate a substantial rise in Ship-to-Ship (STS) transfer operations, often conducted under the radar of enforcement agencies.

These clandestine operations, particularly prevalent in Southeast Asian regions, especially in the waters off Malaysia, present significant challenges to maritime security and pose safety risks to legitimate commercial shipping. They also increase environmental risks to sensitive coastal areas. In 2024, using satellite imagery, over 500 StS ops had been observed in the waters off Eastern Johor, Malaysia, at the edge of their Exclusive Economic Zone (EEZ).  However, this likely represents only a fraction of the total activity due to limitations in satellite coverage and weather-related obscuration.

The risks from these illicit activities are significant.  There is no evidence that the vessels comply with International Maritime Pollution Convention (MARPOL) requirements for notification of the Coastal State and submission of STS plans. Oil spills almost certainly occur during these illicit operations, and oil slicks are regularly observed in these areas. The ships frequently use deceptive practices, including shutting off AIS and also spoofing a false location elsewhere. They conduct these operations immediately adjacent to the busiest shipping lanes leading from the South China Sea into the Singapore Strait. The resulting accidents are inevitable and costly: in May 2023, the Dark Fleet tanker PABLO exploded, killing three seafarers, while in July 2024, CERES I collided with another vessel while operating without broadcasting AIS signals. 

As the global shipping industry and governments grapple with the risks of illicit activity, understanding the growing influence of the Dark Fleet is crucial to safeguarding the integrity of international trade and coastal environments.  Opportunities for international cooperation exist and should be supported and enhanced with additional resources.

President-elect Donald Trump has appointed Representative Mike Waltz of Florida as his national security adviser, a key role that does not require Senate confirmation. In a recent interview, Waltz laid out an outline of a strategy.  “You don’t solve Gaza in Gaza.  You solve it by dealing with Iran. As long as they are flush with cash, the Middle East is never going to have peace.  China buys 90% of Iran’s illicit oil  We’ll be having conversations with China about those purchases.” In November 2024, Iran continued substantial exports to China, reaching 1.45 million barrels per day. 

November 2024 Iran Oil Exports:

*Figures to be updated over the following weeks

The desired outcome of the sanctions program is to reduce the flow of oil out of Iran and the flow of funds into the regime. However, the Dark Fleet activities observed at sea indicate that these illicit networks are growing and generating vast profits through new business models that circumvent the U.S. financial system. The funds accumulated by Iran due to lax sanctions enforcement in previous years have enabled the regime to quickly replace vessels designated for sanctions, further undermining the effectiveness of these measures and perpetuating the cycle of sanctions evasion.

This situation calls for increased international cooperation to raise awareness of the risks from the Dark Fleet activity beyond the financial risks of being placed on a sanctions list.  The International Maritime Organization (IMO) 33rd Assembly adopted an important resolution calling upon its member states, the shipping community, and other stakeholders to take several specific actions:

“RECOMMENDS that port States, when they become aware of any ships intentionally taking measures to avoid detection … to notify the respective ship's flag administration…”

“CALLS UPON coastal States to monitor STS operations in their territorial sea and exclusive economic zone…”

“ENCOURAGES coastal States to collaborate to improve monitoring of these practices and operations…”

“URGES Governments, the Secretary-General, flag State authorities, port State control authorities, ship owners and operators, non-governmental organizations, the private sector including the marine insurance industry, ship brokers and other relevant maritime stakeholders to develop and deliver workshops that focus on enhancing capabilities and due diligence practices for the prevention, detection and reporting of the operation of dark fleets or shadow fleets and illegal activities facilitated by such ships.”

This IMO resolution presents a critical opportunity for international collaboration. Sharing information on the Dark Fleet’s activities—identifying vessels engaged in deceptive practices and illicit transfers—is essential. Capacity-building initiatives for regional coast guards and authorities and legal support for prosecuting violations will strengthen enforcement. Engaging coastal communities, fishing industries, and environmental stakeholders can further amplify awareness of these risks and foster collective action.

Looking ahead to 2025, there is optimism for reducing the risks the Dark Fleet poses. Increased enforcement of sanctions, active information sharing, and enhanced maritime cooperation can collectively make a meaningful impact. However, these efforts must be met with tangible actions. International partnerships will be indispensable in ensuring that the flow of illicit oil—and the resulting financial lifeline to Iran—is effectively curtailed.