Shadow Fleet

The tanker is involved in the transportation of sanctioned Iranian crude oil to China, including from storage facilities in China, which is considered part of an established scheme involving the Iranian military, which profits from the sale of Iranian oil through the vessel. In August 2024, the tanker HEDY (IMO 9212888) of the sanctioned National Iranian Tanker Company (NITC) was transferred from ship to ship and received more than 600,000 barrels of Iranian crude oil. NITC is a subsidiary of the sanctioned National Iranian Oil Company (NIOC), which is one of the largest oil and gas companies in the world and is controlled by the Iranian Ministry of Oil. NIOC and its subsidiaries explore, produce, transport, process and export oil and natural gas in Iran. Oil revenues provide the Iranian regime with the resources to finance its nuclear program, develop advanced drones and missiles, and provide ongoing financial and material support for the terrorist activities of its regional proxies.
The vessel resorts to deceptive, high-risk practices.
On February 06, 2025, USA imposed sanctions on the vessel.
Since December 13, 2025, Ukraine has imposed sanctions on the vessel.

The tanker for the transportation of oil products during the period of the G7+ oil embargo and the price cap policy on russian crude oil/oil products is involved in the transportation of crude oil/oil products from russian ports in the Baltic Sea using deceptive, high-risk practices (disabling AIS, in particular, in the area of the port of Ust-Luga).
The tanker is affiliated through the sanctioned companies Sun Ship Management (UAE), Oil Tankers SCF MGMT FZCO (UAE), Fornax Ship Management FZCO (UAE) with the sanctioned PJSC Sovcomflot, the largest state-owned shipping company in russia for servicing and supporting offshore hydrocarbon production, transportation of russian crude oil, oil products, and liquefied gas. The major charterers of PJSC Sovcomflot's vessels are russia's largest oil and gas companies and traders. PJSC Sovcomflot is involved in servicing major oil and gas projects in russia: Sakhalin-1, Sakhalin-2, Varandey, Prirazlomnoye, Novy Port, Yamal LNG and others.
On May 09, 2025, the United Kingdom imposed sanctions on the tanker as part of the restrictions on the shadow fleet of the russian federation.
Since May 21 and June 3, 2025, the EU and Switzerland, respectively, have imposed sanctions on the vessel for transporting crude oil/petroleum products originating in or exported from rRussia, using irregular shipping practices with a high degree of risk, as specified in Resolution A.1192(33) of the General Assembly of the International Maritime Organization.
In June 2025, Canada imposed sanctions on the vessel.
In August 2025, Ukraine imposed sanctions on the tanker's master.
Since September 18, 2025, Australia has imposed sanctions on the vessel.
Since December 13, 2025, Ukraine has imposed sanctions on the vessel.
The tanker has been flying the russian flag since August 2026.

The tanker is involved in the transportation of crude oil/oil products from russian ports in the Baltic Sea to third countries during the period of the G7+ oil embargo and the price cap policy on russian crude oil/oil products.
The tanker is affiliated through the sanctioned companies Sun Ship Management (UAE), Oil Tankers SCF MGMT FZCO (UAE), Fornax Ship Management FZCO (UAE) with the sanctioned PJSC Sovcomflot, the largest state-owned shipping company in russia for servicing and supporting offshore hydrocarbon production, transportation of russian crude oil, oil products, and liquefied gas. The major charterers of PJSC Sovcomflot's vessels are russia's largest oil and gas companies and traders. PJSC Sovcomflot is involved in servicing major oil and gas projects in russia: Sakhalin-1, Sakhalin-2, Varandey, Prirazlomnoye, Novy Port, Yamal LNG and others.
Since October 2024, the tanker has been operated by Thunder Shipmanagement LLC-FZ (UAE). As of February 14, 2025, the fleet of Thunder Shipmanagement LLC-FZ consists of 21 oil tankers affiliated with the sanctioned PJSC Sovcomflot. The company's fleet includes sanctioned oil tankers, in particular ІМО 9309576, ІМО 9322968, ІМО 9309588, ІМО 9292060, ІМО 9292058, ІМО 9292034, ІМО 9276028, ІМО 9329655, ІМО 9577094 and others.
After the sanctions were imposed, PJSC Sovcomflot transferred dozens of vessels to the ownership of companies it created, including in foreign jurisdictions, in order to circumvent them, and started the practice of constantly 'juggling' (transferring) vessels to related companies. Tankers 're-registered' by PJSC Sovcomflot to related companies continue to transport russian crude oil/oil products under Western sanctions.
On February 24, 2025, the United Kingdom imposed sanctions on the vessel.
Since February 25, March 04, 2025 EU and Switzerland respectively have imposed sanctions on the tanker for transporting crude oil/oil products originating in or exported from russia using irregular and high-risk shipping practices as specified in the International Maritime Organization General Assembly resolution A.1192 (33).
In June 2025, Canada imposed sanctions on the vessel.
In June 2025, Australia imposed sanctions on the vessel.
Since October 30, 2025, New Zealand has imposed sanctions on the tanker.
Since December 13, 2025, Ukraine has imposed sanctions on the vessel.
On February 21, 2026, Ukraine imposed sanctions on the master of the vessel.

The tanker is affiliated with Vision Ship Management LLP, an Indian-based company whose vessels are involved in the transportation of millions of barrels of sanctioned Iranian crude oil for the benefit of the sanctioned China Concord Petroleum Company, which was sanctioned by USA in late 2019 for violating restrictions on the handling and transaction of Iranian oil. On December 03, 2024, USA imposed sanctions on Vision Ship Management LLP for its activities in the oil sector of the Iranian economy.
Previously, RIO NAPO had transported 35 thousand metric tons of Iranian oil to the UAE worth approximately $21.5 million.
On December 03, 2024, USA imposed sanctions on the vessel as a property in which Vision Ship Management LLP has an interest.
Since December 13, 2025, Ukraine has imposed sanctions on the vessel.

The tanker is involved in the export of russian crude oil/oil products under the G7+ oil embargo, the price-cap policy for russian crude oil/oil products, in particular from russian ports in the Pacific region, mainly to China, including with the AIS turned off. The vessel called at a russian port where the price of oil traded constantly above the price cap.
The international non-governmental organization Greenpeace refers to the tanker as part of the shadow fleet of tankers transporting russian crude oil around the world and threatening the environment.
The tanker is affiliated with Surrey Quays Company Limited, which was sanctioned by USA on January 10, 2025 for its activities in the energy sector of the russian economy.
On January 10, 2025, USA imposed sanctions on the tanker, which is considered to be part of the shadow fleet, as a property in which Surrey Quays Company Limited has an interest.
Since February 25, March 04, 2025 EU and Switzerland have respectively imposed sanctions on the tanker for transporting crude oil/oil products originating in or exported from russia using irregular and high-risk shipping practices as specified in the International Maritime Organization General Assembly resolution A.1192 (33); promoting or supporting actions/policies aimed at the exploitation, development or expansion of the energy sector in russia, including energy infrastructure.
On July 21, 2025, the United Kingdom imposed sanctions on the vessel.
In November 2025, Canada imposed sanctions on the vessel.
Since December 13, 2025, Ukraine has imposed sanctions on the vessel.
On February 21, 2026, Ukraine imposed sanctions on the master of the vessel.

The tanker is involved in the export of russian crude oil/oil products under the G7+ oil embargo and the price-cap policy for russian crude oil/oil products, including the disabling of AIS.
The international public organization Greenpeace refers to the tanker as part of the shadow fleet of tankers transporting russian oil around the world and threatening the environment.
The tanker is affiliated with Sino Ship Management Company Limited, which was sanctioned by USA on January 10, 2025 for its activities in the energy sector of the russian economy.
On January 10, 2025, USA imposed sanctions on the tanker, which is considered to be part of the shadow fleet, as a property in which Sino Ship Management Company Limited has an interest.
From July 20, 2025, the EU imposed sanctions on a tanker for transporting crude oil/petroleum products that originate in russia or are exported from russia using irregular and high-risk shipping practices as set out in the International Maritime Organization General Assembly resolution A.1192 (33).
On August 12, 2025, Switzerland imposed sanctions on the vessel.
Since September 12, 2025, he United Kingdom has imposed sanctions on the vessel.
In November 2025, Canada imposed sanctions on the vessel.
Since December 13, 2025, Ukraine has imposed sanctions on the vessel.
On February 21, 2026, Ukraine imposed sanctions on the master of the vessel.

The tanker is involved in the export of russian crude oil/oil products under the G7+ oil embargo and the price-cap policy for russian crude oil/oil products, including with the AIS turned off. The vessel called at a russian port where the price of crude oil was constantly above the upper limit of the price-cap.
The tanker is affiliated with Loengo Shipping and Trader Limited, which was sanctioned by USA on January 10, 2025 for its activities in the energy sector of the russian economy.
On January 10, 2025, USA imposed sanctions on the tanker, which is considered to be a part of the shadow fleet, as a property in which Loengo Shipping and Trader Limited has an interest.
On May 20, 2025, the EU imposed sanctions, which enter into force on May 21, 2025, on the tanker for the transportation of crude oil/petroleum products originating in or exported from russia, using irregular high-risk shipping practices as specified in the International Maritime Organization General Assembly Resolution A.1192(33).
On June 03, 2025, the sanctions imposed by Switzerland on the vessel came into force.
On July 21, 2025, the United Kingdom imposed sanctions on the vessel.
In November 2025, Canada imposed sanctions on the vessel.
Since December 13, 2025, Ukraine has imposed sanctions on the vessel.
On February 21, 2026, Ukraine imposed sanctions on the master of the vessel.

The tanker is involved in the export of russian crude oil/oil products under the G7+ oil embargo and price-cap policy for russian crude oil/oil products, including the use of deceptive practices.
The vessel is affiliated with Maritas Fleet PVT LTD (India), which was the former ISM manager of the tanker. Maritas Fleet PVT LTD was founded in December 2022 in Mumbai. This company is associated with the ISM management of tankers affiliated with the sanctioned company Hennesea Holdings Limited (UAE), which shortly before the price cap policy came into force acquired 18 oil tankers transporting russian sanctioned crude oil/oil products and was sanctioned by USA for violation of the price cap.
The vessel is operated by Avision Shipping Services Private Limited (IMO 6454662), which was sanctioned by USA on January 10, 2025.
On January 10, 2025, the USA imposed sanctions on the vessel.
On February 24, 2025, the United Kingdom imposed sanctions on the vessel.
On February 24, March 04, 2025 EU and Switzerland respectively imposed sanctions on the tanker for transporting crude oil/oil products originating in or exported from russia using irregular and high-risk shipping practices as specified in the International Maritime Organization General Assembly resolution A.1192 (33) (EU sanctions will enter into force on February 25, 2025).
On April 11, 2025, Ukraine imposed sanctions on the master of vessel IMO 9409467.
In June 2025, Canada imposed sanctions on the vessel.
In June 2025, Australia imposed sanctions on the vessel.
According to GISIS IMO data, as of July 17, 2025, the vessel's flag is designated as Guinea False. At the same time, the vessel continues to sail under the flag of Guinea.
Since October 30, 2025, New Zealand has imposed sanctions on the tanker.
Since December 13, 2025, Ukraine has imposed sanctions on the vessel.

The international NGO Greenpeace refers to the tanker as part of the shadow fleet of tankers transporting russian crude oil around the world and threatening the environment.
The tanker, which is considered to be part of the shadow fleet, is involved in the export of russian crude oil/oil products during the period of the G7+ oil embargo on russian oil and the price cap policy on russian crude oil/oil products, in particular, it called at a russian port where the oil price constantly exceeds the upper limit of the price cap.
The vessel is affiliated with Meghan Group Limited, which was sanctioned by USA on January 10, 2025 for its activities in the energy sector of the russian economy.
On January 10, 2025, USA imposed sanctions on the vessel as a property in which Meghan Group Limited has an interest.
After USA sanctions were imposed, the vessel changed its name and flag country.
On May 20, 2025, the EU imposed sanctions, which enter into force on May 21, 2025, on the tanker for the transportation of crude oil/petroleum products originating in or exported from russia, using irregular high-risk shipping practices as specified in the International Maritime Organization General Assembly Resolution A.1192(33).
On June 03, 2025, the sanctions imposed by Switzerland on the vessel came into force.
On July 21, 2025, the United Kingdom imposed sanctions on the vessel.
In November 2025, Canada imposed sanctions on the vessel.
Since December 13, 2025, Ukraine has imposed sanctions on the vessel.
On February 21, 2026, Ukraine imposed sanctions on the master of the vessel.

The tanker, during the period of the G7+ oil embargo and the price-cap policy on russian crude oil/oil products, is engaged in the transportation of russian crude crude oil/oil products from russian ports, in particular, in the Black and Baltic Seas, including the use of deceptive, high-risk practices (turning off AIS) in the Kerch Strait area, where a transshipment hub of russian crude oil/oil products has been established near the russian port of Kavkaz. The tanker called at the russian port, where crude oil is constantly trading above the price cap.
The international NGO Greenpeace refers to the tanker as part of a shadow fleet of tankers transporting russian oil around the world and threatening the environment.
The tanker is affiliated with Aquaquasar Holding Limited, which was sanctioned by USA on January 10, 2025 for its activities in the energy sector of the russian economy.
On January 10, 2025, USA imposed sanctions on the tanker, which is considered to be part of the shadow fleet, as a property in which Aquaquasar Holding Limited has an interest.
On May 20, 2025, the EU imposed sanctions, which will enter into force on May 21, 2025, on the tanker for the transportation of crude oil/petroleum products originating in or exported from russia, using irregular high-risk shipping practices as specified in the International Maritime Organization General Assembly Resolution A.1192(33).
On June 03, 2025, the sanctions imposed by Switzerland on the vessel came into force.
On July 21, 2025, the United Kingdom imposed sanctions on the vessel.
Since October 30, 2025, New Zealand has imposed sanctions on the tanker.
In November 2025, Canada imposed sanctions on the vessel.
Since December 13, 2025, Ukraine has imposed sanctions on the vessel.
On February 21, 2026, Ukraine imposed sanctions on the master of the vessel.

The tanker is engaged in the transportation of sanctioned Iranian and russian crude oil/oil products using deceptive, high-risk practices. The vessel called at a russian port, where the price of oil was constantly trading above the upper limit of the price-cap for russian crude oil/oil products.
The international public organization Greenpeace refers to the tanker as a shadow fleet of tankers transporting russian oil around the world and threatening the environment.
According to United Against Nuclear Iran, the tanker is involved in the transportation of sanctioned Iranian oil and, after Western sanctions were imposed, switched to the transportation of sanctioned russian oil.
Until October 2021, the vessel was affiliated through a number of companies, including the sanctioned Sun Ship Management, with the sanctioned PJSC Sovcomflot, the largest state-owned shipping company in russia for servicing and supporting offshore hydrocarbon production, transportation of russian crude oil, oil products, and liquefied gas. The main charterers of PJSC Sovcomflot's vessels are russia's largest oil and gas companies and traders. PJSC Sovcomflot is involved in servicing major oil and gas projects in russia: Sakhalin-1, Sakhalin-2, Varandey, Prirazlomnoye, Novy Port, Yamal LNG and others.
The tanker is associated with Odine Marine Incorporated, the former owner of the vessel, which was sanctioned by USA on January 10, 2025 for its activities in the energy sector of the russian economy.
On January 10, 2025, USA imposed sanctions on a vessel considered to be part of the shadow fleet as a property in which Odine Marine Incorporated has an interest.
Since September 12, 2025, the United Kingdom has imposed sanctions on the vessel.
In November 2025, Canada imposed sanctions on the vessel.
Since December 13, 2025, Ukraine has imposed sanctions on the vessel.
On February 21, 2026, Ukraine imposed sanctions on the master of the vessel.

During the period of the G7+ oil embargo and the price cap policy on russian crude oil/oil products, the tanker is engaged in the transportation of russian crude oil/oil products from russian ports, in particular, in the Pacific region, mainly to China. The tanker called at a russian port, where the price of oil is constantly trading above the upper limit of the price cap.
The international public organization Greenpeace refers to the tanker as part of the shadow fleet of tankers transporting russian oil around the world and threatening the environment.
The tanker is affiliated with the sanctioned company Global Industrial and Engineering Supply Ltd as the previous owner and operator of the vessel, which was sanctioned by USA in 2020 for supplying 300 metric tons of graphite to an Iranian sanctioned company, which is critical for Iran's metallurgical industry.
Since January 2022, the tanker has been owned and operated by Merluza Group Limited, which was sanctioned by USA on January 10, 2025 for its activities in the energy sector of the russian economy.
On January 10, 2025, USA imposed sanctions on the vessel, which is considered to be part of the shadow fleet, as a property in which Merluza Group Limited has an interest.
On February 24, March 04, 2025 EU and Switzerland respectively imposed sanctions on the tanker for transporting crude oil/oil products originating in or exported from russia using irregular and high-risk shipping practices as specified in the International Maritime Organization General Assembly resolution A.1192 (33); promoting or supporting actions/policies aimed at the exploitation, development or expansion of the energy sector in russia, including energy infrastructure (EU sanctions will enter into force on February 25, 2025).
On July 21, 2025, the United Kingdom imposed sanctions on the vessel.
In August 2025, Ukraine imposed sanctions on the tanker's master.
In November 2025, Canada imposed sanctions on the vessel.
Since December 13, 2025, Ukraine has imposed sanctions on the vessel.