TOA PAYOH

The tanker, during the period of the G7+ oil embargo and the price cap policy on russian crude oil and petroleum products, is involved in the export of russian petroleum products—specifically from russian ports on the Black Sea—and is engaged in deceptive, high-risk practices (such as the deactivation of AIS, particularly in the area of the Kerch Strait in the Black Sea).
In 2025, the tanker made calls at the Sheshkharis oil terminal (Port of Novorossiysk), which is a transshipment complex and the terminus of the main pipelines of JSC "Chernomortransneft" (TIN 2315072242, under U.S. sanctions)—a subsidiary of the sanctioned russian PJSC "Transneft" (TIN 7706061801).
In March 2025, the tanker called at the port of Kamysh-Burun in the temporarily occupied territories of Ukraine.
In May 2024, STS transfers took place near Romania involving the tanker IMO 9220938, which was subject to U.S. sanctions in October 2024 for illegal shipments of Iranian oil, and the tanker IMO 9637973, affiliated with the russian company Volgotrans LLC, which is subject to Ukrainian sanctions.
The transshipment at sea of russian-origin crude oil and petroleum products using the STS method makes it possible to conceal ownership and the origin of the cargo, and to legalize their supply to the EU, the U.S., and other countries. In turn, the sale of oil and petroleum products on the global market allows the russian federation to accumulate significant financial resources in its state budget, which are used, among other things, to build up the military capabilities of the aggressor state and to provide material support for russia’s military operations on the territory of Ukraine.
In February 2025, the tanker exported 106.16 barrels of russian petroleum products from Novorossiysk to Egypt.
In March 2025, the vessel exported 146.7 barrels of russian petroleum products from the port of Taman to Syria (Baniyas); the seller of the cargo was Slavyansk ECO (LLC "Slavyansk ECO," TIN 2370000496).
In April 2025, the tanker exported 331,700 barrels of petroleum products from the "Sheshkharis" terminal at the port of Novorossiysk to Turkey (Marmara).
Also, in April and May 2025, the vessel exported 230,800 and 231,500 barrels of petroleum products of the Ilyskiy Refinery (TIN 2308128110), respectively, from the Sheshkharis terminal at the Port of Novorossiysk to Turkey (Marmara).
In June 2025, the tanker exported several shipments of petroleum products of the Ilyskiy Refinery from the "Sheshkharis" terminal at the Port of Novorossiysk: 164,200 barrels to Benin and 83,800 barrels to Togo (Lomé). Also in June 2025, the vessel exported petroleum products from the "Sheshkharis" terminal at the port of Novorossiysk to Ghana.
In December 2025, the tanker shipped several batches of petroleum products of the Ilyskiy Refinery (165,900, 55,300, and 82,900 barrels) from the Sheshkharis terminal at the Port of Novorossiysk for export.
The vessel is affiliated with the sanctioned company Fractal Marine DMCC (UAE)—one of the leading operators in 2022–2023 of the so-called shadow fleet involved in the export of russian crude oil and petroleum products.
The shipping company Fractal Marine DMCC (UAE) was established shortly before the G7 countries imposed a price cap on russian oil following russia’s full-scale invasion of Ukraine and played a significant role in the transportation of russian oil. Fractal Marine DMCC managed a fleet of 28 tankers as an intermediary between ship owners and charterers.
After being sanctioned, Fractal Marine DMCC attempted to appeal the sanctions imposed by the United Kingdom but lost in court. Following this, the company "transferred" its fleet to other companies. Thus, the tankers previously managed by Fractal Marine DMCC were transferred to new management companies, specifically The Zulu Ships Management & Operation - Sole Proprietorship LLC (UAE).
The management of the tanker IMO 9298492 from October 2024 to July 2025 was carried out by The Zulu Ships Management & Operation - Sole Proprietorship LLC.
The vessel IMO 9298492 is part of the vast shipping empire of Iranian oil magnate and major arms supplier to the russian fderation Mohammad Hossein Shamkhani.
Mohammad Hossein Shamkhani’s network consists of a vast fleet of vessels, ship management companies, and front companies that launder billions in profits from global sales of Iranian and russian crude oil and petroleum products, most often to buyers in China. The network takes significant measures to conceal its operations and obscure its ties to the Shamkhani family, Iran, and russia.
The companies BPT Shipping Co LLC (UAE), Fractal Marine DMCC (UAE), Wanta Shipping LLC-FZ (UAE), and The Zulu Ships Management and Operation - Sole Proprietorship LLC (UAE), with which the tanker IMO 9298492 is affiliated, are among a number of companies that have played a significant role in the management and operation of the Shamkhani network’s tanker fleet.
On July 30, 2025, the United States imposed sanctions on the tanker IMO 9298492.
In April 2026, the EU imposed sanctions on the vessel.
As of April 29, 2026, Ukraine has imposed sanctions on the vessel.