Marine vessels

The vessel is affiliated with the company Alya Marine Sendirian Berad, which was sanctioned by USA on October 11, 2024 for engaging in a significant number of transactions involving the purchase, acquisition, sale, transportation or marketing of crude oil/petroleum products from Iran. On October 11, 2024, USA imposed sanctions on the tanker as a property in which the sanctioned company Alya Marine Sendirian Berhad has an interest.

The tanker is affiliated with Delnaz Ship Management Sdn Bhd, which was sanctioned by USA on October 11, 2024 as part of the expansion of restrictions on Iran's oil/petrochemical sector. On October 11, 2024, USA imposed sanctions on the tanker as a property in which Delnaz Ship Management Sdn Bhd has an interest.

The tanker is involved in the export of russian oil (petroleum products) from the port of Ust-Luga (russia) in the Baltic Sea in May-June 2024, from an unspecified port in the Black Sea due to the shutdown of AIS in October 2023 to the Indian port of Sikka. The vessel, through related companies, in particular sanctioned Stream Ship Management FZCO, is affiliated with the sanctioned PJSC Sovcomflot, the largest state-owned shipping company in russia for the maintenance and provision of marine hydrocarbon extraction, transportation of russian oil, petroleum products, and liquefied gas. The main charterers of Sovcomflot vessels are the largest oil and gas companies and traders of russia. Sovcomflot participates in the maintenance of large oil and gas projects in russia: Sakhalin-1, Sakhalin-2, Varandey, Pryrazlomnoye, Novyy Port, Yamal LNG, others. Before the full-scale russian invasion of Ukraine, the company's fleet consisted of about 145 vessels. After the application of sanctions, PJSC Sovcomflot transferred dozens of vessels to the ownership of companies it created, including those in foreign jurisdictions, in order to circumvent them, starting the practice of constant 'juggling' (transferring) vessels to related companies. The tankers 'transferred' by PJSC Sovcomflot to related companies are, according to experts, part of the so-called 'shadow tanker fleet' of the russian federation to continue sales of russian oil, petroleum products, and liquefied gas under Western sanctions. On October 17, 2024, United Kingdom imposed sanctions on tankers of the russian so-called "shadow fleet", including the tanker ІМО 9413573. On January 10, 2025, USA imposed sanctions on the vessel. On February 21, 2025, Canada 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).

The tanker is involved in violation of the G7 and EU oil embargo on the export of russian crude oil to the EU and the export of russian oil to third countries. The vessel exported russian crude oil from the russian port of Primorsk in the Baltic Sea in May 2024 and transported it to a transshipment point near the port of Nador (Morocco) and the Spanish port of Melilla. The vessel is affiliated with a sanctioned company One Moon Marine Services LLC (UAE) with a non-transparent organizational and ownership structure. One Moon Marine Services LLC is involved in a network of companies along with other UAE-based companies - Alqutb Alshamali Marine, Almuhit Alhadi Marine, Oceanlink Maritime, Symphony Marine - to which tankers carrying russian oil (oil products) were 'registered', managed, in particular, by one of the leading operators of the so-called 'shadow' fleet - the sanctioned company Radiating World Shipping Services. The constant change of owners and managers of vessels to avoid sanctions and conceal the true beneficiaries of the vessels is a typical phenomenon for the so-called 'shadow' fleet involved in the russian oil and oil products trade. On October 17, 2024, the United Kingdom imposed sanctions on tankers of the russian so-called 'shadow' fleet, including the tanker ІМО 9285835. On February 21, 2025, Canada 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); 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).

The tanker is affiliated with Delnaz Ship Management Sdn Bhd, which was sanctioned by USA on October 11, 2024 as part of the expansion of restrictions on Iran's oil/petrochemical sector. On October 11, 2024, USA imposed sanctions on the tanker as a property in which Delnaz Ship Management Sdn Bhd has an interest.

The tanker was used by the sanctioned company China Concord Petroleum Co. Limited to deliver millions of barrels of Iranian oil from the sanctioned National Iranian Oil Company (NIOC) to China. The National Iranian Oil Company (NIOC) 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. The oil deals of NIOC, including its subsidiaries, are used to generate revenue for the IRGC-QF (Islamic Revolutionary Guard Corps) and Hizballah (Hezbollah). After russia's full-scale invasion of Ukraine, namely in July 2022 during putin's visit to Tehran, the National Iranian Oil Company and the russian sanctioned PJSC Gazprom signed a memorandum of understanding on strategic cooperation in the oil and gas sector worth about $40 billion. China Concord Petroleum Co., Limited is a key intermediary that helps Iran and Venezuela export crude oil to circumvent sanctions restrictions. On October 11, 2024, as part of the expansion of restrictions on Iran's oil/petrochemical sector, USA imposed sanctions on the vessel as a property in which Delnaz Ship Management Sdn Bhd (the previous manager of the tanker) has an interest.

The vessel is involved in the delivery of Iranian oil to China. On October 11, 2024, as part of the expansion of restrictions on Iran's oil/petrochemical sector, USA imposed sanctions on the vessel as a property in which Davina Shipping Inc, which was also sanctioned by USA on October 11, 2024, has an interest.

The vessel participated in the transfer of hundreds of thousands of barrels of condensate from a vessel of the sanctioned National Iranian Tanker Company (NITC), and also carried out an STS transfer with an NITC vessel near Singapore for the transportation of tens of thousands of metric tons of condensate from the South Pars field (the world's largest natural gas condensate field located in the Persian Gulf, owned by Iran and Qatar). The National Iranian Tanker Company (NITC) is a subsidiary of the sanctioned National Iranian Oil Company, which is controlled by the Iranian Ministry of Oil. The National Iranian Tanker Company is responsible for the transportation of Iranian crude oil intended for export, plays a significant role in oil deals that are used to generate profits for the IRGC-QF (Islamic Revolutionary Guard Corps) and Hizballah (Hezbollah). On October 11, 2024, as part of the expansion of sanctions against Iran's oil/petrochemical sector, USA imposed sanctions on the vessel as a property in which Elza Shipping SA, which was also sanctioned by USA on October 11, 2024, has an interest.

The tanker is affiliated with the companies Engen Management NV, based in Suriname, Gabbaro Ship Services PVT LTD, based in India, which were sanctioned by USA on October 11, 2024 pursuant to EO 13846 because of the companies' involvement in a significant number of transactions in the purchase, acquisition, sale, transportation or marketing of crude oil or petroleum products from Iran. On October 11, 2024, USA imposed sanctions on the tanker as a property in which Gabbaro Ship Services PVT LTD has an interest.

The tanker is involved in the transportation of Iranian oil to numerous refineries in China, transshipment by STS with a vessel of the sanctioned National Iranian Tanker Company (NITC) near Singapore for the transportation of tens of thousands of metric tons of Iranian crude oil. The National Iranian Tanker Company (NITC) is a subsidiary of the sanctioned National Iranian Oil Company, which is controlled by the Iranian Ministry of Oil. The National Iranian Tanker Company is responsible for the transportation of Iranian crude oil intended for export, and plays a significant role in oil deals that are used to generate profits for the IRGC-QF (Islamic Revolutionary Guard Corps) and Hizballah (Hezbollah). The tanker is affiliated with Cathay Harvest Marine Ltd (Hong Kong), which on October 11, 2024, within the framework of expanding restrictions on the oil/petrochemical sector of Iran in accordance with EO 13846, was sanctioned by USA due to the fact that the company on or after November 05, 2018, provided material assistance, sponsorship or financial, material or technological support, or provided goods or services in support of the National Iranian Oil Company (NIOC). Also, on October 11, 2024, USA imposed sanctions on the tanker as a property in which Cathay Harvest Marine Ltd has an interest under EO 13846.

The tanker is affiliated with Celia Armas Ltd, a Hong Kong-based company, which was sanctioned by USA on October 11, 2024 pursuant to EO 13846 for engaging in a significant number of transactions involving the purchase, acquisition, sale, transportation or marketing of crude oil or petroleum products from Iran. According to the American human rights group United Against Nuclear Iran (UANI), which monitors Iran-related tanker traffic using satellite data, the vessel was involved in the transportation of Iranian oil and switched to transporting russian oil. Since the beginning of russia's full-scale invasion of Ukraine in February 2022, more than 90 vessels that previously helped Tehran export Iranian export oil are now helping russia transport russian oil/oil products. In May 2022, UANI first predicted that russia would turn to a 'ghost armada' to ensure oil flows to its Chinese partner. On October 11, 2024, the USA imposed sanctions on the tanker as a property in which Celia Armas Ltd has an interest.

The vessel is affiliated with the company Alya Marine Sendirian Berad, which was sanctioned by USA on October 11, 2024 for engaging in a significant number of transactions involving the purchase, acquisition, sale, transportation or marketing of crude oil/petroleum products from Iran. According to the American human rights group United Against Nuclear Iran (UANI), which monitors Iran-related tanker traffic using satellite data, the vessel was involved in the transportation of Iranian oil and switched to transporting russian oil. Since the beginning of russia's full-scale invasion of Ukraine in February 2022, more than 90 vessels that previously helped Tehran export Iranian export oil are now helping russia transport russian oil/oil products. In May 2022, UANI first predicted that russia would turn to a 'ghost armada' to ensure oil flows to its Chinese partner. On October 11, 2024, USA imposed sanctions on the tanker as a property in which the sanctioned company Alya Marine Sendirian Berhad has an interest.