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4/4/2024

Treasury Targets Network Facilitating Shipments Valued in Hundreds of Millions for Iranian Military | U.S. Department of …

Treasury Targets Network Facilitating Shipments Valued in
Hundreds of Millions for Iranian Military
April 4, 2024

WASHINGTON — Today, the Department of the Treasuryʼs O ice of Foreign Assets Control
(OFAC) is taking additional action against Iranian military revenue generation, targeting
Oceanlink Maritime DMCC for facilitating the shipment of Iranian commodities on behalf of
Iranʼs Armed Forces General Sta (AFGS) and Ministry of Defense and Armed Forces Logistics
(MODAFL). OFAC is also identifying 13 vessels managed by Oceanlink Maritime DMCC as
blocked property. The Oceanlink Maritime DMCC-managed vessel HECATE recently loaded
Iranian commodities valued at over $100 million dollars via a ship-to-ship (STS) transfer from
another sanctioned tanker, the DOVER, on behalf of Iranʼs Sepehr Energy Jahan Nama Pars
(Sepehr Energy), which OFAC sanctioned in November 2023 for its role selling Iranian
commodities for the AFGS and MODAFL.
“We are focused on disrupting Iranʼs ability to finance its terrorist proxy and partner groups
and support to Russiaʼs war of aggression against Ukraine,” said Under Secretary of the
Treasury for Terrorism and Financial Intelligence Brian E. Nelson. “The United States will
continue to use our full range of tools to target the illicit funding streams that enable Iranʼs
destabilizing activities in the region and around the world.”
OFAC is also updating the Specially Designated Nationals and Blocked Persons List (SDN List)
to reflect that the name of OFAC-sanctioned vessel YOUNG YONG (IMO: 9194127) has been
changed to the SAINT LIGHT, possibly to obfuscate its identity. The SAINT LIGHT, which is
also operating under the name STELLAR ORACLE, conducted an STS transfer on March 27,
2024 with a sanctioned vessel operated by the National Iranian Tanker Company (NITC), the
HAWK (IMO: 9362061), from which it loaded over $100 million worth of Iranian commodities.
The HAWK had loaded the same cargo on March 22, 2024 via an STS transfer from the vessel
KOHANA (IMO: 9254082), which OFAC sanctioned on February 27, 2024 for its role in
attempting to ship MODAFL-owned commodities.
Todayʼs action is being taken pursuant to the counterterrorism authority in Executive Order
(E.O.) 13224, as amended. OFAC designated Sepehr Energy pursuant to E.O. 13224, as
amended, on November 29, 2023, for having materially assisted, sponsored, or provided
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Treasury Targets Network Facilitating Shipments Valued in Hundreds of Millions for Iranian Military | U.S. Department of …

financial, material, or technological support for, or goods or services to or in support of
MODAFL. OFAC designated MODAFL pursuant to E.O. 13224 on March 26, 2019 for providing
material support to Iranʼs Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF).

MODAF LʼS ILLICIT COMMERCIAL ACT IVIT Y
Oceanlink Maritime DMCC operates a fleet of over one dozen vessels which are deeply
involved in the shipment of Iranian commodities, including on behalf of Iranʼs military. On
March 25, 2024, the DOVER (IMO: 9218466), a vessel operated by NITC and carrying over $100
million worth of commodities on behalf of Sepehr Energy, conducted an STS transfer with the
Comoros-flagged, Oceanlink Maritime-managed HECATE (IMO: 9233753), using obfuscation
techniques to conceal the locations of the vessels.
Sepehr Energy has also shipped Iranian commodities using the Comoros-flagged ANTHEA
(IMO: 9281683) and BOREAS (IMO: 9248497), both of which are managed by Oceanlink
Maritime DMCC. Oceanlink Maritime DMCC also manages the Comoros-flagged CAPE GAS
(IMO: 9002491), GLAUCUS (IMO: 9337389), OCEANUS GAS (IMO: 9397080), and HEBE (IMO:
9259185), the Antigua and Barbuda-flagged CALYPSO GAS (IMO: 9131101) and MERAKI (IMO:
9194139), the Belize-flagged ELSA (IMO: 9256468) and BAXTER (IMO: 9282522), the Panamaflagged DEMETER (IMO: 9258674) and the Cook Islands-flagged OUREA (IMO: 9350422). The
CAPE GAS, GLAUCUS, OCEANUS GAS, HEBE, CALYPSO GAS, MERAKI, ELSA, BAXTER, DEMETER,
and OUREA have all shipped Iranian commodities, some as recently as March of this year.
Oceanlink Maritime DMCC, which is based in the UAE, is being designated pursuant to
E.O. 13224, as amended, for having materially assisted, sponsored, or provided financial,
material, or technological support for, or goods or services to or in support of, Sepehr Energy.
The HECATE, ANTHEA, BOREAS, CAPE GAS, GLAUCUS, OCEANUS GAS, HEBE, CALYPSO GAS,
MERAKI, ELSA, BAXTER, DEMETER, and OUREA are being identified as property in which
Oceanlink Maritime DMCC has an interest.

SANCT IONS IMPLICAT IONS
As a result of todayʼs action, all property and interests in property of the designated persons
described above that are in the United States or in the possession or control of U.S. persons
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
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exempt, OFACʼs regulations 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.
In addition, financial institutions and other persons that engage in certain transactions or
activities with the sanctioned entities and individuals may expose themselves to sanctions or
be subject to an enforcement action. The prohibitions include the making of any contribution
or provision of funds, goods, or services by, to, or for the benefit of any designated person, or
the receipt of any contribution or provision of funds, goods, or services from any such person.
The power and integrity of OFAC sanctions derive not only from OFACʼs ability to designate
and add persons to the SDN List, but also from its willingness to remove persons from the
SDN List consistent with the law. The ultimate goal of sanctions is not to punish, but to bring
about a positive change in behavior. For information concerning the process for seeking
removal from an OFAC list, including the SDN List, please refer to OFACʼs Frequently Asked
Question 897 here. For detailed information on the process to submit a request for removal
from an OFAC sanctions list, please click here.
Click here for more information on the individuals and entities designated today.
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