Smooth sailing for Iran's blacklisted fleet
April 9, 2010
In September 2008, the United States blacklisted Iran’s
state shipping company and its fleet of 123 vessels because of the
company's role in supplying Iran’s weapon programs. Soon after, in an
effort to evade this sanction, the company began a large-scale
re-labeling of its ships, giving them new names, new managers, new
“owners” – in short, new identities (
see table below). The U.S. blacklist has not kept up with these changes, so it is being circumvented by Iran with relatively little effort.
The United States accused the
Islamic Republic of Iran Shipping Lines
(IRISL) of carrying military cargo to Iran and of helping Iran
circumvent U.N. sanctions. The U.S. action, which was taken pursuant
to Executive Order 13382, froze all IRISL assets under U.S.
jurisdiction and banned all transactions with U.S. parties. The ban
extended to all of the company’s owned or controlled subsidiaries or
sub-units, including individual marine vessels. The Treasury
Department’s Office of Foreign Assets Control (OFAC), which is
responsible for enforcing the ban, published the names and unique IMO
(International Maritime Organization) numbers of the 123 vessels, and
instructed U.S. banks to reject any funds transfer referencing the
name of a banned ship. Freight forwarders and shippers were also
forbidden from chartering, booking cargo on, or otherwise dealing with
the blacklisted vessels.
IRISL has responded to Treasury’s action with a wholesale – and
ongoing – renaming of its ships. The response has often included
dropping “Iran” from ship names. “Iran Brave,” for example, has become
“Margrave,” “Iran Dolphin” has become “Alameda,” and “Iran Matin” has
become “Abba,” to name just a few. In all, at least 80 vessels have
been renamed so far; 40 of these had the word “Iran” in their names
before the change, and all 40 emerged without it.
In addition to renaming sanctioned vessels, IRISL began transferring
nominal ownership of the ships to shell companies, mainly in Malta,
Germany, and Hong Kong. IRISL already had operations in these
locations, making them convenient spots to set up new front companies.
IRISL (Malta) Limited,
for example, now shares its office space in a low-rise apartment
building in the city of Sliema with a host of newly formed companies,
including Jackman Shipping Company, Newhaven Shipping Company, Lancing
Shipping Company, Oxted Shipping Company, and ten others, each of
which is now the new registered owner of an IRISL vessel. The same
pattern was followed at IRISL’s German branch. The Hamburg address of
IRISL Europe GmbH is
now also home to “Seventh Ocean GmbH and Co.,” “Eleventh Ocean GmbH
and Co.,” and “Twelfth Ocean GmbH and Co.” These companies are the new
owners of the sanctioned vessels formerly known as “Seventh Ocean,”
“Eleventh Ocean,” and “Twelfth Ocean,” which have been re-named
“Gabion,” “Daffodil,” and “Dandle,” respectively.
These are not the only steps IRISL has taken to distance itself from
its vessels. In 2008, the company managed almost all of its ships.
Since then, a company called “Soroush Sarzamin Asatir SSA,” based in
Tehran, has emerged to take on the role of ship manager for more than
half of the sanctioned vessels. In fact, this company seems to deal
exclusively in sanctioned, renamed IRISL vessels.
The combined effect of all these changes has been to make it harder
for honest companies to comply with U.S. sanctions. Whereas running a
compliance check on a transaction involving one of these ships in late
2008 would have raised several red flags, changes made by IRISL since
then mean that the same transaction today would probably appear
clean. Only each ship’s unique IMO number is unchanged. But these
numbers do not always appear on cargo documents, such as letters of
credit. So, any U.S. company that screens a vessel against Treasury’s
sanctions list without checking the IMO number is at risk of taking part
in an illegal transaction.
The United States expected such evasive measures from Iran. In a
State Department press release announcing the sanctions, it was noted
that IRISL had “deliberately misled maritime authorities through
deceptive techniques.” And at the time, the director of Treasury’s
Office of Foreign Assets Control promised that Treasury would update its
sanctions list “in two weeks, if we learn about additional identities
of vessels or if we see IRISL changing the names of its vessels.”
Unfortunately, this has not happened; there appears to be no sustained
U.S. effort to track these changes and to add new vessel names to
Treasury’s blacklist.
In sum, Iran has made more of an effort to circumvent the sanctions
imposed on IRISL than the United States has made to enforce them. This
pattern must change if sanctions are to be effective. The United
States must work to discover and publish changes to IRISL vessel names
and ownership, and must add to its blacklist front companies created
for the purpose of evading sanctions.
Following is a list of the IRISL vessels that the United States
sanctioned in 2008 and that have since been renamed. This list is
current as of March 2010. None of the new names have been added to the
U.S. government’s blacklist. (See
information on the sources used to compile this table.)
| New name |
Name when sanctioned |
Present owner |
Present ship manager |
Present flag |
IMO number |
| Abba |
Iran Matin |
IRISL |
IRISL |
Iran |
9051624 |
| Accurate |
Drifter |
Sackville Holdings Ltd. |
Soroush Sarzamin Asatir SSA |
Hong Kong |
8320169 |
| Acena |
Iran Kermanshah |
Acena Shipping Co. Ltd. |
Soroush Sarzamin Asatir SSA |
Cyprus |
9213399 |
| Acrobat |
Devotional |
Partner Century Limited |
Soroush Sarzamin Asatir SSA |
Hong Kong |
8309684 |
| Admiral |
Dais |
New Synergy Ltd. |
Soroush Sarzamin Asatir SSA |
Hong Kong |
8309696 |
| Adrian |
Delight |
Sandford Group Limited |
Soroush Sarzamin Asatir SSA |
Hong Kong |
8320133 |
| Adventist |
Iran Madani |
Kingdom New Ltd. |
Soroush Sarzamin Asatir SSA |
Hong Kong |
8309622 |
| Aerolite |
Delegate |
Logistic Smart Ltd. |
Soroush Sarzamin Asatir SSA |
Hong Kong |
8320121 |
| Afflatus |
Developer |
Ideal Success Investments Ltd. |
IRISL |
Hong Kong |
8309660 |
| Agean |
Dynamize |
Insight World Ltd. |
Soroush Sarzamin Asatir SSA |
Hong Kong |
8309634 |
| Agile |
Decorous |
Concept Giant Ltd. |
Soroush Sarzamin Asatir SSA |
Hong Kong |
8309658 |
| Ajax |
Iran Ghazi |
Sino Access Holding Limited |
Soroush Sarzamin Asatir SSA |
Hong Kong |
8309672 |
| Alameda |
Iran Dolphin |
Advance Novel Ltd. |
Soroush Sarzamin Asatir SSA |
Hong Kong |
8320195 |
| Alias |
Devotee |
Alpha Effort Ltd. |
Soroush Sarzamin Asatir SSA |
Hong Kong |
8309608 |
| Amitees |
Iran Jomhuri |
IRISL |
IRISL |
Iran |
7632826 |
| Amplify |
Diplomat |
Smart Day Holdings Limited |
Soroush Sarzamin Asatir SSA |
Hong Kong |
8309701 |
| Angel |
Dapper |
Neuman Limited |
Soroush Sarzamin Asatir SSA |
Hong Kong |
8309646 |
| Anil |
Dandy |
Trade Treasure Limited |
Soroush Sarzamin Asatir SSA |
Hong Kong |
8320157 |
| Anoush |
Iran Azadi |
n/a |
n/a |
Iran |
7632838 |
| Apollo |
Iran Navab |
System Wise Ltd. |
Soroush Sarzamin Asatir SSA |
Hong Kong |
8320145 |
| Aquarian |
Dignified |
Great Method Ltd. |
Soroush Sarzamin Asatir SSA |
Hong Kong |
8309610 |
| Assa |
Iran Entekhab |
IRISL |
IRISL |
Iran |
7632814 |
| Atlantic |
Dreamland |
New Desire Ltd. |
Soroush Sarzamin Asatir SSA |
Hong Kong |
8320183 |
| Atrium |
Iran Hamzeh |
True Honour Holdings Ltd. |
Soroush Sarzamin Asatir SSA |
Hong Kong |
8320171 |
| Attribute |
Diamond |
Best Precise Ltd. |
Soroush Sarzamin Asatir SSA |
Hong Kong |
8309593 |
| Barsam |
Iran Shariat |
IRISL |
IRISL |
Iran |
8107581 |
| Bluebell |
Iran Gilan |
Gomshall Shipping Co. |
Soroush Sarzamin Asatir SSA |
Malta |
9193202 |
| Chastity |
Shaafi |
Ifold Shipping Company Limited |
Soroush Sarzamin Asatir SSA |
Malta |
9386500 |
| Chimes |
Vaafi |
Jackman Shipping Company |
Soroush Sarzamin Asatir SSA |
Malta |
9387786 |
| Daffodil |
Eleventh Ocean |
Eleventh Ocean GmbH & Co. |
Martime |
Germany |
9209324 |
| Dandelion |
New State |
Logistic Smart Ltd. |
Hafiz Darya Shipping Co. |
Malta |
9209336 |
| Dandle |
Twelfth Ocean |
Twelfth Ocean GmbH & Co. |
IRISL |
Germany |
9209348 |
| Danoosh |
Iran Bagheri |
n/a |
n/a |
n/a |
7428811 |
| Decker |
Fifth Ocean |
Fifth Ocean GmbH & Co. |
Hafiz Darya Shipping Co. |
Malta |
9349667 |
| Decretive |
Sixth Ocean |
Sixth Ocean GmbH and Co. |
Hafiz Darya Shipping Co. |
Malta |
9349679 |
| Despina |
Iran Kolahdooz |
IRISL |
IRISL |
Iran |
7428809 |
| Dinna |
Iran Broojerdi |
IRISL |
IRISL |
Iran |
7502722 |
| Gabion |
Seventh Ocean |
Seventh Ocean GmbH and Co. |
IRISL |
Germany |
9165786 |
| Galax |
Ninth Ocean |
Ninth Ocean GMBH |
IRISL |
Germany |
9165798 |
| Garland |
Lucky Man |
Kingdom New Ltd. |
IRISL |
Malta |
9165839 |
| Gladiolus |
Tenth Ocean |
Tenth Ocean GmbH & Co. |
IRISL |
Germany |
9165815 |
| Goldenrod |
Lucky Lily |
Insight World Ltd. |
Soroush Sarzamin Asatir SSA |
Malta |
9165827 |
| Gomidas |
Iran Esteghlal |
IRISL |
IRISL |
Iran |
7620550 |
| Hootan |
Iran Sepah |
IRISL |
IRISL |
Iran |
7375363 |
| Horsham |
Iran Bam |
Horsham Shipping Co. Ltd. |
Soroush Sarzamin Asatir SSA |
Malta |
9323833 |
| Kijea |
Iran Baghaei |
IRISL |
IRISL |
Iran |
7502734 |
| Lancelin |
Iran Yazd |
Lancelin Shipping |
Soroush Sarzamin Asatir SSA |
Cyprus |
9213387 |
| Lantana |
Ocean Candle |
Neuman Ltd. |
Soroush Sarzamin Asatir SSA |
Malta |
9167253 |
| Lavender |
Pretty Sea |
New Desire Limited |
Soroush Sarzamin Asatir SSA |
Malta |
9167277 |
| Lilied |
Sea State |
Sackville Holdings Ltd. |
Soroush Sarzamin Asatir SSA |
Malta |
9167265 |
| Limnetic |
Sea Flower |
Partner Century Ltd. |
Soroush Sarzamin Asatir SSA |
Malta |
9167289 |
| Lodestar |
Sea Bloom |
Irisl |
Soroush Sarzamin Asatir SSA |
Malta |
9167291 |
| Margrave |
Iran Brave |
Best Precise Ltd. |
Soroush Sarzamin Asatir SSA |
Malta |
9051650 |
| Marigold |
Brightness |
Concept Giant Ltd. |
Soroush Sarzamin Asatir SSA |
Malta |
9051648 |
| Markarid |
Iran Deyanat |
IRISL |
IRISL |
Iran |
8107579 |
| Mulberry |
Brilliance |
IRISL |
IRISL |
Malta |
9051636 |
| Pantea |
Iran Adl |
IRISL |
IRISL |
Iran |
8108559 |
| Parmida |
Iran Afzal |
IRISL |
IRISL |
Iran |
8105284 |
| Sadaf Poshtiban |
Iran Hormuz 26 |
Darya Fan Qeshm Industries Co. |
Darya Fan Qeshm Industries Co. |
Iran |
8422084 |
| Sakas |
Iran Piroozi |
Ashtead Shipping Co. Ltd. |
IRISL |
Iran |
9283007 |
| Sepanta |
Iran Ardebil |
Farnham Shipping Co. Ltd. |
IRISL |
Iran |
9284154 |
| Sepitam |
Iran Ilam |
Effingham Shipping Co. Ltd. |
IRISL |
Iran |
9283033 |
| Sewak |
Iran Fars |
Cobham Shipping Co. |
IRISL |
Iran |
9283021 |
| Shere |
Iran Tabas |
Shere Shipping Co. Ltd. |
Soroush Sarzamin Asatir SSA |
Malta |
9305192 |
| Silver Craft |
Iran Kerman |
Kerman Shipping Co. Ltd. |
Hafiz Darya Shipping Co. |
Malta |
9209350 |
| Silver Zone |
Iran Bushehr |
Bushehr Shipping Co. Ltd. |
Hafiz Darya Shipping Co. |
Malta |
9270658 |
| Simber |
Iran Yasooj |
Dorking Shipping Co. Ltd. |
IRISL |
Iran |
9284142 |
| Tabak |
Iran Amanat |
IRISL |
IRISL |
Iran |
8112990 |
| Tongham |
Iran Birjand |
Tongham Shipping Company |
Soroush Sarzamin Asatir SSA |
Malta |
9305219 |
| Tuchal |
Iran Tuchal |
Fifteenth Ocean GmbH & Co. |
IRISL |
Malta |
9346536 |
| Uppercourt |
Iran Bojnoord |
Uppercourt Shipping Co. |
Soroush Sarzamin Asatir SSA |
Malta |
9305207 |
| Visea |
Iran Zanjan |
Byfleet Shipping Co. Ltd. |
IRISL |
Iran |
9283019 |
| Vobster |
Persian Gulf |
Vobster Shipping Co. |
Soroush Sarzamin Asatir SSA |
Malta |
9305221 |
| Zaven |
Iran Takhti |
n/a |
IRISL |
Iran |
7602194 |
| Zawa |
Iran Azarbayjan |
IRISL |
IRISL |
Iran |
9193185 |
| Zoorik |
Iran Teyfouri |
n/a |
n/a |
n/a |
7602211 |
| |
| Note on sources: |
| This table was compiled using data drawn from
several sources, including the Germanischer Lloyd and Det Norske
Veritas vessel registers. It is believed to be accurate as of
3/17/2010, but is highly likely to change thereafter. |
No comments:
Post a Comment