Today, the Department of the Treasury’s Office of Foreign Assets Control (OFAC), and the U.S. Department of State are imposing sanctions on over 30 persons and vessels in multiple jurisdictions for their role in brokering the sale and transportation of Iranian petroleum-related products. Among those sanctioned today are oil brokers in the United Arab Emirates (UAE) and Hong Kong, tanker operators and mangers in India and People’s Republic of China (PRC), the head of Iran’s National Iranian Oil Company, and the Iranian Oil Terminals Company, whose operations help finance Iran’s destabilizing activities. The vessels sanctioned today are responsible for shipping tens of millions of barrels of crude oil valued in the hundreds of millions of dollars.
“Iran continues to rely on a shadowy network of vessels, shippers, and brokers to facilitate its oil sales and fund its destabilizing activities,” said Secretary of the Treasury Scott Bessent. “The United States will use all our available tools to target all aspects of Iran’s oil supply chain, and anyone who deals in Iranian oil exposes themselves to significant sanctions risk.”
Today’s action is being taken pursuant to Executive Orders 13902 and 13846, which target Iran’s petroleum and petrochemical sectors, and marks the second round of sanctions targeting Iranian oil sales since the President issued National Security Presidential Memorandum 2 on February 4, 2025, ordering a campaign of maximum pressure on Iran and to reduce Iran’s oil exports to zero.
oversIGHT of iranian oil exports
Hamid Bovard serves as Iran’s Deputy Minister of Petroleum and chief executive officer of the National Iranian Oil Company (NIOC), which is responsible for the exploration, production, refining, and export of oil and petroleum products in Iran. Through its direct oversight of Iran’s oil industry, NIOC plays a key role in underwriting the regionally destabilizing activities of Iran’s military and its proxy groups, including the Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF). The Iranian government allocates billions of dollars’ worth of oil each year to its armed forces to supplement their annual budget allocations.
NIOC was designated pursuant to counterterrorism authority E.O. 13224, as amended, on October 26, 2020, for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, the IRGC-QF.
The Iran-based Iranian Oil Terminals Company (IOTC), managed by Abbass Asadrouz, is a NIOC subsidiary that oversees all operations at Iran’s oil terminals, including Kharg Island Oil Terminal, through which a majority of Iranian oil flows, and South Pars Condensate Terminal, which accounts for 100 percent of Iran’s gas condensate exports. Sayyed Ali Miri and Gholamhossein Gerami manage the Kharg Island Oil Terminal and South Pars Condensate Terminal, respectively. Iran’s remaining oil exports depart from terminals along the Caspian Sea, including the North Oil Terminal, headed by Ali Moalemi.
Hamid Bovard and the Iranian Oil Terminals Company are being designated pursuant to E.O. 13902 for operating in the petroleum sector of the Iranian economy. Sayyed Ali Miri, Ali Moalemi, Gholamhossein Gerami, and Abbass Asadrouz are being designated pursuant to E.O. 13902 for acting or purporting to act for or on behalf of, directly or indirectly, IOTC.
OIL BROKERS
Iran relies on brokers outside of Iran to facilitate the sale and transport of its crude oil to end users abroad, largely in the UAE and PRC. UAE-based Petroquimico FZE has purchased tens of millions of dollars’ worth of petroleum products from NIOC. In November 2024, Petroquimico FZE used the Barbados-flagged CASINOVA, which is also known as YING GE, (IMO: 9280366), owned, managed, and operated by Liberia-based Le Monde Marine Services Limited, to transport over 200,000 barrels of Iranian oil to the UAE.
Similarly, Hong Kong-based oil broker Petronix Energy Trading Limited (Petronix Energy) has purchased hundreds of thousands of metric tons of Iranian oil from sanctioned Naftiran Intertrade Company, the marketing arm of NIOC, for onward shipment to the PRC. In 2024, Petronix Energy used the Panama-flagged MENG XIN (IMO 9271406) and the Cook Islands-flagged PHOENIX I (IMO 9236248), both of which are being identified by the State Department as blocked property today, to transport the oil.
Petroquimico FZE, Petronix Energy, and Le Monde Marine Services Limited are being designated pursuant to E.O. 13902 for operating in the petroleum sector of the Iranian economy. The CASINOVA is being identified pursuant to E.O. 13902 as property in which Le Monde Marine Services Limited has an interest.
Shadow FLEET OIL SHIPMENTS
Sanctioned Iranian tankers rely on ship-to-ship transfers outside of jurisdictional port limits with non-sanctioned vessels to transport petroleum to foreign customers, obfuscating the oil’s Iranian origin. In September 2024, the Panama-flagged URGANE I (IMO: 9231901), managed and operated by PRC-based Nycity Shipmanagement Co Ltd (Nycity Shipmanagement), loaded Iranian Pars crude oil via a ship-to-ship transfer with a tanker owned by the sanctioned National Iranian Tanker Company. URGANE I has transported multiple Iranian petroleum shipments to the PRC. Like Nycity Shipmanagement, India-based Flux Maritime LLP has served as the technical manager of a vessel that loaded hundreds of thousands of barrels of heavy Iranian crude oil via a ship-to-ship transfer.
Flux Maritime LLP and Nycity Shipmanagement Co Ltd are being designated pursuant to E.O. 13902 for operating in Iran’s petroleum sector. The URGANE I is being identified as property in which Nycity Shipmanagement Co Ltd has an interest.
The Panama-flagged tankers LYDIA II (IMO: 9365776), AYDEN (IMO: 9365764), and FIONA (IMO: 9365752) have transported multiple shipments of Iranian oil to refineries in the PRC. Seychelles-based shell companies Sunny Land Trading Ltd, Green Garden Trading Ltd, and Artemis Heart Ltd serve as the owners, managers, and operators of the LYDIA II, the AYDEN, and the FIONA, respectively.
Sunny Land Trading Ltd, Green Garden Ltd, and Artemis Heart Ltd are being designated pursuant to E.O. 13902, for operating in petroleum sector of the Iranian economy. The LYDIA II is being identified as property in which Sunny Land Trading Ltd has an interest. The AYDEN is being identified as property in which Green Garden Trading Ltd has an interest. The FIONA is being identified as property in which Artemis Heart Ltd has an interest.
STATE DEPARTMENT DESIGNATIONS
The U.S. Department of State is designating eight entities based in Iran, India, Malaysia, Seychelles, and the UAE for their involvement in the sale, purchase, and transportation of Iranian petroleum. Additionally, eight vessels are being identified as blocked property in which these entities have an interest.
Iran-based Kangan Petro Refining Company; India-based BSM Marine Limited Liability Partnership, Austinship Management Private Limited, Cosmos Lines Inc; UAE-based Alkonost Maritime DMCC and Octane Energy Group FZCO; Malaysia-based IMS Ltd; andSeychelles-based Oceanend Shipping Ltd are being designated pursuant to E.O 13846 for having knowingly engaged in a significant transaction for the purchase, acquisition, sale, transport, or marketing of petroleum or petroleum products, or petrochemical products from Iran.
The Gabon-flagged YATEEKA (IMO: 9191553) is being identified pursuant to E.O. 13846 as property in which BSM Marine Limited Liability Partnership has an interest. The Cook Islands-flagged MENG XIN (IMO: 9271406) and PHOENIX I (IMO: 9236248) are being identified pursuant to E.O. 13846 as property in which Alkonost Maritime DMCC has an interest. The Eswatini-flagged AMAK (IMO: 9244635) is being identified pursuant to E.O. 13846 as property in which Austinship Management Private Limited has an interest. The Panama-flagged VIOLET 1 (IMO: 9154000), PETERPAUL (IMO: 9163269) and CHAMTANG (IMO: 9212400) are being identified pursuant to E.O. 13846 as property in which IMS Ltd has an interest. The Gambia-flagged ASTERIX (IMO: 9181194) is being identified pursuant to E.O. 13846 as property in which Oceanend Shipping Ltd has an interest.
SANCTIONS IMPLICATIONS
As a result of today’s action, all property and interests in property of the designated person(s) described above that are in the United States or in the possession or control of U.S. persons is/are blocked and must be reported to OFAC. In addition, any entities that are owned, directly or indirectly, individually or in the aggregate, 50 percent or more by one or more blocked persons are also blocked. Unless authorized by a general or specific license issued by OFAC or exempt, U.S. sanctions generally prohibit all transactions by U.S. persons or within (or transiting) the United States that involve any property or interests in property of designated or otherwise blocked persons.
Violations of U.S. sanctions may result in the imposition of civil or criminal penalties on U.S. and foreign persons. OFAC may impose civil penalties for sanctions violations on a strict liability basis. OFAC’s Economic Sanctions Enforcement Guidelines provide more information regarding OFAC’s enforcement of U.S. economic sanctions. In addition, financial institutions and other persons may risk exposure to sanctions for engaging in certain transactions or activities with designated or otherwise blocked persons.