The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has announced a new wave of sanctions targeting Iran’s oil and liquefied petroleum gas (LPG) networks.
This latest move highlights OFAC’s relentless focus on disrupting Iran’s illicit energy trade and signals important trends that compliance professionals need to monitor closely.
To help you stay ahead, the team at Pole Star Global, together with key partner Blackstone Compliance Services, has distilled the key insights from this round of sanctions. The following article breaks down these insights, providing practical guidance to ensure your compliance programmes remain robust and proactive.
31 Tankers Designated Across Multiple Fleets
In this latest round of sanctions, OFAC has targeted 31 tanker vessels, many of which operate within major Dark Fleet actors.
Pole Star Global and Blackstone Compliance Services’ Deep Blue Intelligence (DBI) had flagged these vessels well over a year before the official designations.
Several of these ships have been highlighted in DBI’s case studies, webinars, and training programmes, all designed to help compliance officers spot and mitigate maritime sanctions risks worldwide.
The “Innovative” Network and Its Turkish Connection
One tranche of sanctions focused on vessels belonging to a ship operator named Innovative Ukraine SC (“Innovative”), which was not listed directly in the sanctions package but was identified by DBI. Innovative, in turn, is controlled by Boss Petrol BRP, a Turkish firm.
Although Boss Petrol’s director has not been sanctioned, he is reported to operate through a complex web of Turkish front companies to transport goods for Iran’s Triliance group. This group is linked to the Islamic Revolutionary Guard Corps (IRGC) and a frequent target of U.S. sanctions.
This action highlights OFAC’s growing willingness to penetrate layers of intermediaries, exposing and disrupting the front companies that facilitate trade for sanctioned Iranian entities.
Aqua Spirit Case Study: Unravelling a Complex Shipping Network
Aqua Spirit is owned, operated, or managed by the following companies: Boss PRP Group Petrol, Innovative Ukraine SC, or Tethis Shipping.
- As mentioned above, Boss PRP Group Petrol is a Turkish company, first appearing online in 2019.
- Innovative Ukraine SC and Tethis Shipping are Ukrainian companies.
Boss Petrol appears to be the global beneficial owner (GBO) of several vessels. However, many of these ships are managed through Innovative Ukraine, a company that existed before the war.
As noted in OFAC’s designations, most vessels managed by Boss Petrol and/or Innovative Ukraine SC are believed to operate on behalf of the Triliance network. DBI flagged two of these ships, which were specifically identified in the Triliance Leaks as transporting Iranian-origin goods.
Boss Petrol appears to use multiple companies owned or managed by its director, to conduct transactions involving Iranian petrochemicals. One such entity is Petro Pasha, a petrochemical trading firm also directed by that individual.
For example, in May 2023, email correspondence between a Triliance representative, an Iranian glassware company, and Petro Pasha detailed a shipment of $9.5 million in petrochemicals to China.
In this transaction, Petro Pasha acted as the seller, but the goods were Iranian in origin, with payment ultimately going to the Iranian glass company.
Some vessels managed by Boss PRP are operated by Front Way Ship Management & Operations LLC, a UAE company registered in 2022, with a website created in March 2023.
Front Way’s website is linked to two other “Dark Fleet” operators, both of which manage ships involved in spoofing activity related to Iran and Venezuela.
These connections suggest that the group of companies may share mutual interests or coordinate operations.
Looking at the movement history of Aqua Spirit, the vessel appears to have engaged in spoofing between 29 April and 8 May 2024, appearing stationary over waters more than 1,000 fathoms deep, consistent with known spoofing behaviour. Satellite imagery from 4 May 2024 showed no vessel present in the reported area.
The same vessel carried out similar spoofing events on the following dates:
- 15 January – 16 February 2024, at the same coordinates
- 5 – 20 December 2023, near 24°50.782′ N, 57°09.034′ E
This case study of the Aqua Spirit and its associated entities illustrates the intricate nature of the shipping networks used to transport Iranian petrochemicals. OFAC’s latest round of sanctions appears to be penetrating and exposing the layers of sanctions evasion within these networks, an area that Pole Star Global and key partner, Blackstone Compliance Services, have been analysing and investigating for years.
Sea Ship Management and the Expanding “Dark Fleet”
A second wave of designations focused on vessels connected to Sea Ship Management LLC, a UAE-based company incorporated after 2022 that shares an address with several other known Dark Fleet operators.
These ships primarily transport LPG cargoes for Iran and, notably, almost all engage in AIS spoofing, a clear indicator of sanctions evasion.
The move highlights OFAC’s increasing focus on the operational enablers of Iran’s maritime networks, going beyond simply targeting end users to disrupt the systems that make illicit trade possible.
Revisiting the Kunlun Legacy Fleet
Several vessels included in this round of designations are part of the “Kunlun Legacy” fleet, a network linked to Kunlun Holding Group Ltd., a Chinese company previously subject to secondary sanctions for its dealings with the IRGC.
The ongoing activity of Kunlun-linked ships highlights the enduring nature of older sanctions networks and underscores the complex challenge OFAC faces in dismantling deeply entrenched maritime operations.
Expanding the Scope: Rizhao Shihua Crude Oil Terminal
In a significant step beyond merely targeting vessels and operators, OFAC also blacklisted the Rizhao Shihua Crude Oil Terminal.
DBI had previously reviewed communications between Dark Fleet actors and this terminal, indicating that these sanctions were long overdue.
This move reflects a strategic evolution in enforcement: OFAC is increasingly focusing on the broader ecosystem that enables Iran’s illicit oil trade, from port operators and flag registries to even sham P&I clubs that provide cover for these networks.
How to Stay Compliant Amid Evolving Iranian Sanctions
Clients of Deep Blue Intelligence (DBI) are already benefiting from DBI’s robust monitoring of Iran’s and Russia’s Dark Fleet.
DBI watchlists track over 1,350 tanker vessels, including more than 700 linked to known or suspected Iranian dealings. DBI clients also receive in-depth training on how Iran circumvents sanctions at sea and through financial channels.
Complementing these capabilities, Pole Star Global’s PurpleTRAC customers also benefit from this leading vessel screening and tracking solution. They can screen vessels and associated parties for sanctions, while receiving automatic alerts for dark fleet activity, spoofing, ship-to-ship transfers, and other risks highlighted in OFAC advisories.
With attempts to evade Iran-related sanctions on the rise, ensuring your controls are up to the task has never been more critical. Safeguard your operations today by connecting with a member of our team at [email protected].