Shipping

According to its Annual Report filed with the SEC for fiscal year 2018: "The vessel Myrto made a call to the port of Bandar Imam Khomeini on April 12, 2018, discharging soybeans, and remained in the port of Bandar Imam Khomeini during 2018 for ten days. During this time the Myrto was on time charter to Cargill at a gross rate of $8,000 per day.

The aggregate gross revenue attributable to these ten days that our vessel remained in the port of Bandar Imam Khomeini was $80,000. As we do not attribute profits to specific voyages under a time charter, we have not attributed any profits to the voyages which included this port call. Our charter party agreements for our vessels restrict the charterers from calling in Iran in violation of U.S. sanctions, or carrying any cargo to Iran which is subject to U.S. sanctions."

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"The vessel Thetis made a call to the port of Bandar Imam Khomeini on February 25, 2017, discharging corn, and remained in the port of Bandar Imam Khomeini during 2017 for seven days. During this time the Thetis was on time charter to Transgrain Shipping B.V., Rotterdam at a gross rate of $5,150 per day." (SEC Disclosure 2017).

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According to its Annual Report filed with the SEC for fiscal year 2016: "Pursuant to Section 13(r) of the Exchange Act, we note that for the period covered by this annual report, four of our vessels made one port call each to Iran in 2016.

• The vessel Amphitrite made a call to the port of Bandar Imam Khomeini on February 24, 2016, discharging corn, and remained in the port of Bandar Imam Khomeini during 2016 for seven days. During this time the Amphitrite was on time charter to Bunge S.A. at a gross rate of $7,700 per day.
• The vessel Artemis made a call to the port of Bandar Imam Khomeini on October 4, 2016, discharging sugar, and remained in the port of Bandar Imam Khomeini for 20 days. During this time the Artemis was on time charter to Bunge S.A. at a gross rate of $5,350 per day.
• The vessel Melite made a call to the port of Bandar Imam Khomeini on March 4, 2016, discharging corn, and remained in the port of Bandar Imam Khomeini for eight days. During this time the Melite was on time charter to Cargill International S.A. at a gross rate of $7,250 per day.
• The vessel Myrto made a call to the port of Bandar Imam Khomeini on March 3, 2016, discharging soya bean meal and pellets, and remained in the port of Bandar Imam Khomeini for 34 days. During this time the Myrto was on time charter to Cargill International S.A. at a gross rate of $6,000 per day."

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According to its Annual Report filed with the SEC for fiscal year 2015: "Pursuant to Section 13(r) of the Exchange Act, we note that for the period covered by this annual report, the vessels Amphitrite and Clio made five port calls to Iran in 2015 for a combined length of 60 days. The vessel Amphitrite made calls to the port of Bandar Imam Khomeini on December 29, 2014 (discharging corn), April 29, 2015 (discharging soya beans), September 6, 2015 (discharging corn) and November 28, 2015 (discharging maize), and remained in the port of Bandar Imam Khomeini during 2015 for 50 days in the aggregate. The vessel Clio made a call to the port of Bandar Imam Khomeini on October 27, 2015, discharging corn, and remained in the port of Bandar Imam Khomeini for 10 days.  During this time the Amphitrite was on time charter to Bunge S.A. at a gross rate of $11,300 per day and the Clio was on time charter to Transgrain Shipping B.V at a gross rate of $6,500 per day. Our aggregate gross revenue attributable to these 60 days of port calls was approximately $3.2 million, less 5% commissions paid to third parties. As we do not attribute profits to specific voyages under a time charter, we have not attributed any profits to the voyages which included these port calls.  Our charter party agreements for the Amphitrite and Clio restrict the charterers from calling in Iran in violation of U.S. sanctions, or carrying any cargo to Iran which is subject to U.S. sanctions. However, there can be no assurance that the Amphitrite, Clio or another of our vessels will not, from time to time in the future on charterer's instructions, perform voyages which would require disclosure pursuant to Exchange Act Section 13(r)."

"Arkas Holding and IRISL, which is a maritime company of Islamic Republic of Iran, dissolved the partnership. Within the scope of developing relationships between Turkey and Iran; the shares of the IRISL Anadolu Shipping Agency, which was established in 2016 by Arkas Holding and IRISL that is a maritime company of Islamic Republic of Iran; were transferred to Iranians." (Maritime, "Arkas Holding and IRISL Dissolve the Partnership," 11/7/2018).

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"Arkas Holding has said it signed a memorandum of understanding with the Islamic Republic of Iran Shipping Lines (IRISL) to establish a Turkey-based joint venture to offer maritime transportation and logistics services across the Mediterranean Sea.

Arkas Chairman Lucien Arkas, and IRISL Executive Board Chairman Dr. Mohammad Saeedi attended the signing ceremony, which was held in IRISL’s head office in Tehran, said the İzmir-based Arkas said in a written statement on April 12." (April 12, 2016).

"Epic Gas’ vessels have recently started calling at Iranian ports and subject to a benign sanction environment it expects the trade to develop steadily. Recovering production in Iraq is driving growth in LPG volumes moving from oil fields in the south to a recently restored marine terminal at the port of Basrah, which has commenced exports in pressurised vessels to nearby markets such as Pakistan." (February 10, 2017)

As of July 2020, China Shipbuilding remains on the Pennsylvania Treasury's List of Scrutinized Companies Determined as Having Involvement In Iran because of oil-related investment of US $20 million since 1996. 

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As of June 8, 2020, China Shipbuilding is listed on the Pennsylvania Department of General Services Iran Free Procurement List. Entities included on this list are ineligible to enter into a contract with the Commonwealth of Pennsylvania for goods and services worth at least $1,000,000 per sections 3501-3506 of the Commonwealth Procurement Code, 62 Pa. C.S. §§ 3501-3506.  

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In 2015, the North Carolina General Assembly enacted the Iran Divestment Act of 2015 to implement the authority granted by the Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010. The Act prohibits the North Carolina Retirement Systems or the Department from investing in funds with individuals or companies engaging in certain defined investment activities in Iran. In addition, State agencies, local government units, and other political subdivisions of the State are prohibited from contracting with companies on the Department’s “Final Divestment and Do-Not-Contract List-Iran.” As of August 30 2019, China Shipbuilding is listed as a restricted company.  

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As of October 2019, China Shipbuilding remains on the Pennsylvania Treasury's List of Scrutinized Companies Determined as Having Involvement In Iran because of oil-related investment of US $20 million since 1996. 

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In 2017, the states of  North Carolina, listed CSIC on its Iran scrutinized companies list rendering China Shipbuilding ineligible for investment and/or state contracting.

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In 2014, China Shipbuilding was added to the Pennsylvania Treasury's List of Scrutinized Companies Determined as Having Involvement in Iran because of oil-related investment of US $20 million since 1996.

As of May 17, 2021, Iowa's Public Employee's Retirement System lists Capital Product Partners on its Iran Scrutinized Companies List.

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As of August 15, 2019, Iowa's Municipal Fire & Police Retirement System lists Capital Product Partners on its Iran Scrutinized Companies List.

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According to its Annual Report filed with the SEC for fiscal year 2018: "In March 2018, one vessel owned by us and chartered under a time charter party to Product & Crude Tanker Chartering Inc. (“PCTC”), a subsidiary of Capital Maritime, our sponsor, made a port call to Iran to load crude oil. This port call represented less than 0.05% of the total port calls made by all our vessels in 2018. It occurred while the vessel was chartered out to an unaffiliated sub-charterer, under the instructions of such sub-charterer. As the vessel owner, we earned revenues at the agreed daily charter rate from PCTC under the applicable time charter. PCTC in turn earned revenues at the agreed freight rate from the sub-charterer that employed the vessel. CPLP’s aggregate revenue attributable to the number of days that our vessel under time charter remained in a port in Iran was approximately $0.1 million, representing less than 0.04% of our total revenues during the year ended December 31, 2018. This vessel was part of the Tanker Business spun-off in March 2019. In addition, in February 2018, the vessel M/T Amore Mio II, which we sold in October 2018, made a port call to Iran to load crude oil while employed under a voyage charter to an unaffiliated third party. This port call represented less than 0.05% of the total port calls made by all the vessels owned by CPLP in 2018. The aggregate revenue attributable to this voyage was approximately $1.5 million, representing approximately 0.5% of our total revenues during the year ended December 31, 2018. We do not attribute profits to specific voyages.

Other than as described above, no vessel owned or chartered by Capital Maritime made any port calls to countries targeted by economic sanctions during 2018.

As part of the voyage charter arrangements between us and third-party charterers or sub-charterers, we or our Manager may pay fees and expenses related to the port calls made in Iran through a private third-party agent in Iran appointed by the third-party charterer or sub-charterer. In 2018, no such payments were made for re-fueling or bunkers for the vessels making such port calls. We believe the port calls to Iran were made in full compliance with applicable economic sanctions laws and regulations, including those of the United States, the European Union and other relevant jurisdictions. See also “Item 4B: Business Overview—Regulation” for information on the port calls made by certain our vessels and those of our affiliates to Iran."

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According to its Annual Report filed with the SEC for fiscal year 2017: "In 2017, vessels owned by CPLP and chartered under time charter parties to Product & Crude Tanker Chartering Inc. (“PCTC”), a subsidiary of CMTC, our sponsor and the sole member of our general partner, made the following port calls to Iran and Sudan: four port calls to Iran to load crude oil, three port calls to Iran to discharge vegetable oils and two port calls to Sudan to discharge palm and vegetable oils. In addition, in 2017, our vessel, the M/T Aiolos, made a port call to Sudan to discharge fuel oil while employed under a voyage charter to an unaffiliated third party.

These port calls represented approximately 0.5% of the total port calls made by all the vessels owned by CPLP in 2017. They each occurred while the respective vessel was chartered out to an unaffiliated charterer or sub-charterer under the instructions of such charterer or sub-charterer. With respect to the vessels chartered out to PCTC, as the vessel owner, we earned revenues at the agreed daily charter rates from PCTC under the applicable time charters. PCTC in turn earned revenues at the agreed freight or hire rate from the sub-charterers that employed the vessels. CPLP’s aggregate revenue attributable to the number of days that our vessels under time charters remained in ports in Iran or Sudan and the port call made by the M/T Aiolos in Sudan described above was approximately $1.5 million, representing approximately 0.6% of our total revenues during the year ended December 31, 2017. We do not attribute profits to specific voyages.

Further, in 2017, vessels owned or chartered-in by CMTC (including the vessels chartered-in from CPLP by PCTC under time charters as described above) made the following port calls to Iran and Sudan: 12 port calls to Iran to load crude oil, five port calls to Iran to discharge vegetable oils, one port call to Sudan to load molasses and two port calls to Sudan to discharge palm and vegetable oils.

These port calls represented 1.7% of the total port calls made by all the vessels owned or chartered-in by CMTC in 2017. They each occurred while the respective vessel was chartered out to an unaffiliated charterer or sub-charterer under the instructions of such charterer or sub-charterer. The aggregate revenue attributable to the number of days that the vessels under time charters remained in ports in Iran or Sudan and port calls in Iran and Sudan made by vessels under voyage charters to unaffiliated charterers or sub-charterers was approximately $35.2 million, representing approximately 10.0% of CMTC’s total revenues during the year ended December 31, 2017. CMTC does not attribute profits to specific voyages.

As part of the voyage charter arrangements between CMTC and third-party charterers or sub-charterers, CMTC or its manager may pay fees and expenses related to the port calls made in Iran through a private third-party agent in Iran appointed by the third-party charterer or sub-charterer, which in 2017 did not include any payments for refueling or bunkers for the vessels making such port calls."

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In 2017, the state of Iowa listed Capital Product Partners on its Iran scrutinized companies list rendering Capital Product Partners ineligible for investment and/or state contracting.

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Stated in its 2016 SEC report “Of the vessels in our fleet, one vessel made one port call to Iran, which represented approximately 0.2% of our total calls in 2015. In addition, a vessel owned by our affiliate, Capital Maritime, made one port call to Iran. As part of the voyage charter arrangements between our affiliate Capital Maritime and third-party charterers, Capital Maritime or its manager may pay fees and expenses related to the port calls made in Iran through a private third-party agent in Iran appointed by the third-party charterer, which in 2015 did not include any payments for refueling or bunkers for the vessels making such port calls.” 

BBC Chartering vessels BBC Colorado and BBC Maple Lotta call at Iranian ports.

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According to publicly accessible ship-monitoring data, since January 1, 2016, BBC-operated vessels have called at Iranian ports over162 occasions.

"India is inching closer to establishing its presence near the Persian Gulf with billionaires Gautam Adani and the Essar group's Ruia brothers flagging interest in managing terminals at Iran's Chabahar port, which India first agreed to develop 14 years ago, according to people with knowledge of the matter. Adani Ports & Special Economic Zone Ltd., operator of India's largest port, and Essar Ports Ltd. are among companies that have expressed an interest in managing and operating two terminals at Chabahar, said the people, asking not to be identified discussing confidential matters. India Ports Global Ltd., the company mandated to drive India's investments in overseas ports, on March 17 invited firms to express interest if they want to be considered for a strategic partnership." (Bloomberg, "Indian Billionaires Are Interested Managing Delayed Iran Port: Sources," 3/30/2017).

"The Adani Group has removed a ban on exports and imports to and from Afghanistan, Pakistan and Iran at its Mundra port, reversing an order made in October. The company said it removed the ban after consultations with terminal and vessel operators, customs broker associations and importers who had agreed to adhere to security compliances. The Adani Group had banned the import and export of containerised cargo from Afghanistan, Iran and Pakistan at its Mundra port on October 11. Mundra is the largest commercial port in India and emerged as the largest container handling port in the financial year 2020-21 (surpassing JNPT) with a market share of 32% (a gain of around 5%), according to the conglomerate's latest annual report." (The Economic Times, "Adani Group opens cargo traffic from Iran, Afghanistan and Pakistan at Mundra port," 12/10/21)

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According to publicly accessible ship-monitoring data, SDN-listed vessel ALVAN (IMO: 9165798) visited the Port of Mundra, Adani Mundra Container Terminal in May 2019.

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In December 2017 Adani Ports was shortlisted on a tender floated by India Ports Global Ltd to manage, operate and maintain the container and multi-purpose terminals at Chabahar port in Iran.

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In April 2017 Adani expressed an interest in managing and operating two terminals at Iran’s Chabahar port.

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"India is inching closer to establishing its presence near the Persian Gulf with billionaires Gautam Adani and the Essar group's Ruia brothers flagging interest in managing terminals at Iran's Chabahar port, which India first agreed to develop 14 years ago, according to people with knowledge of the matter. Adani Ports & Special Economic Zone Ltd., operator of India's largest port, and Essar Ports Ltd. are among companies that have expressed an interest in managing and operating two terminals at Chabahar, said the people, asking not to be identified discussing confidential matters. India Ports Global Ltd., the company mandated to drive India's investments in overseas ports, on March 17 invited firms to express interest if they want to be considered for a strategic partnership." (Bloomberg, "Indian Billionaires Are Interested Managing Delayed Iran Port: Sources," 3/30/2017).

“While NITC continues to be the market leader in terms of the number of ships deployed for loading crude from Iran, other companies with ships loading from the country include Dynacom, Delta Tankers, Euronav, Polembros, COSCO, Avin International, Olympic Shipping and Management, New Shipping and Thenamaris, it said.” (Platts, "Tankers: Sharp Rise in Iran's Crude Oil Shipments to Europe," March 2017).

“While NITC continues to be the market leader in terms of the number of ships deployed for loading crude from Iran, other companies with ships loading from the country include Dynacom, Delta Tankers, Euronav, Polembros, COSCO, Avin International, Olympic Shipping and Management, New Shipping and Thenamaris, it said.” (Platts, "Tankers: Sharp Rise in Iran's Crude Oil Shipments to Europe," March 2017).