Marine vessels

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.

The tanker is involved in the delivery of numerous shipments of Iranian oil to refineries in China, is affiliated with the company Rita Shipping Inc (Marshall Islands). On October 11, 2024, within the framework of expanding restrictions on Iran's petroleum/petrochemical sector, USA imposed sanctions on Rita Shipping Inc. pursuant to 13846 for providing material assistance, sponsorship or financial, material or technological support, or goods or services in support of the sanctioned National Iranian Oil Company (NIOC) on or after November 05, 2018. 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. On October 11, 2024, USA imposed sanctions on the tanker as a property in which Rita Shipping Inc has an interest pursuant to EO 13846.

The tanker is affiliated with Glazing Future Management NV, a Suriname-based company, which was sanctioned by USA on October 11, 2024 under EO 13846 in connection with the company's 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 Glazing Future Management NV has an interest.

During the period of the G7 and EU oil embargo and the price-cap policy on russian oil, the tanker is involved in the export of russian oil from the russian ports of Primorsk, Ust-Luga in the Baltic Sea, Kozmino in the Pacific region to third countries, in particular, India and China. The Israeli Ministry of Defense accuses the tanker ІМО 9235725 of transporting Iranian oil for the Quds Force and Hezbollah. The international NGO Greenpeace refers to the tanker as part of the shadow fleet of tankers that transport russian oil around the world and threaten the environment. The tanker is affiliated with the Cypriot company Lagosmarine Ltd (НE 402876) as the former manager of the vessel. The company's director is Δακης Μαυρουδης, who, in turn, is a director of another Cypriot company, Sparta Shipmanagement Limited (ΗΕ 393698). Lagosmarine Ltd and Sparta Shipmanagement Limited are registered at the same address in Cyprus. At the same time, Sparta Shipmanagement Limited is affiliated with Latvian citizen Alexey Haliavins, who in 2024 'helped' one of the largest russian oil and gas companies, Surgutneftegaz, to earn $1.4 billion on oil sales above the price ceiling for russian oil set by sanctions. In 2022, Haliavins claimed to be the general manager of Sparta Shipmanagement Limited, as well as the chairman of the board of directors and ultimate beneficial owner of the OGC group. Three Dubai-based companies are associated with Oleksiy Haliavins: Black Pearl Energy Trading LLC, OGC Shipping LLC, and Conmar Maritime. In 2023, Black Pearl Energy Trading LLC and OGC Shipping LLC purchased about 38 million barrels of oil from the russian company Surgutneftegaz at an average price of $83.7 per barrel, which exceeds the price cap for russian oil. In January-May 2024, only Black Pearl Energy Trading bought oil from the russian company, purchasing more than 20.6 million barrels at $83.7. As a result, the russian Surgutneftegaz earned about $1.4 billion bypassing the price ceiling. At the same time, tankers registered to Lagosmarine Ltd, which is affiliated with Sparta Shipmanagement Limited through a joint director, are constantly making voyages between the russian ports of Primorsk, Ust-Luga, Kozmino and India and China. According to customs documents, the same routes were used to move oil sold to Dubai companies linked to Haliavins. In his LinkedIn profile, Haliavins lists himself as a beneficiary and CEO of Conrad Management Company, which is listed as a sponsor company in the UAE residence permits of employees of the russian state-owned company JSC Foreign Economic Association Promsyryoimport (TIN 9704027750, sanctioned by USA and Ukraine). This russian company is involved in schemes to supply Iranian oil to Syria and the TOT of Crimea. The shadow tanker fleet continues to generate multibillion-dollar revenues for the kremlin by circumventing sanctions by disguising its activities under third-country flags, using complex schemes to conceal owners, and poses significant environmental safety hazards with significant economic costs to coastal countries and/or the international community due to the outdated and inadequately insured shadow fleet tankers.

During the period of the G7 and EU oil embargo and price-cap policy on russian crude oil, the tanker is involved in the export of russian oil from russian ports in the Baltic, Black seas, and the Pacific region, mainly to China. According to the USA-based 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 in March 2022. 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. The tanker was illegally transporting hundreds of thousands of metric tons of Iranian oil on behalf of, among others, the sanctioned National Iranian Oil Company (NIOC). The National Iranian Oil Company (NIOC) is one of the largest oil and gas companies in the world and is controlled by the Ministry of Oil of Iran. NIOC and its subsidiaries explore, produce, transport, process and export oil and natural gas in Iran. The oil deals of NIOC, including its subsidiaries, provide the Iranian regime with 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 international public organization Greenpeace refers to the tanker as a shadowy fleet of tankers transporting russian oil around the world and threatening the environment. On December 03, 2024, USA imposed sanctions on the tanker as part of the restrictions on vessels that play a critical role in the transportation of illicit Iranian petroleum to foreign markets. 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).

Since September 2022, the tanker has been exporting russian oil mainly to China from the russian ports of Kozmino in the Pacific region and Primorsk in the Baltic Sea. The vessel is certified by Nippon Kaiji Kyokai (IACS). The vessel is affiliated with Shanghai Legendary Ship MGMT (China), whose fleet is involved in the export of sanctioned Iranian oil. In November 2022, United Against Nuclear Iran (UANI) included the tanker MIN HANG (IMO 9257137), affiliated with Shanghai Legendary Ship MGMT, in a public list of vessels suspected of involvement in the illegal transportation of Iranian oil. russia has created its own shadow tanker fleet, mostly of old tankers, many of which have experience in operating under sanctions imposed on regimes such as Iran. Since the beginning of russia's full-scale invasion of Ukraine in February 2022, more than 90 vessels that previously helped Tehran export Iranian oil are now helping russia transport russian oil/oil products. In May 2022, UANI predicted that russia would use a 'ghost armada' to ensure that excess profits from oil exports flow to its Chinese partner, in particular. The international NGO Greenpeace refers to the tanker as part of the shadow fleet of tankers transporting russian oil around the world and threatening the environment. Oil exports from russia are the most important source of income for the regime of the aggressor country to finance the war against Ukraine. From February 2022 to November 22, 2024, russia earned almost 546 billion euros in revenues from oil exports (69% of all revenues from fossil fuel exports). In 2023, about a third of all tax revenues in russia came from the sale of oil and gas. The tax on oil production collected by the russian federation in 2023 amounted to 8.9 trillion rubles, or 31% of total federal revenues. According to the CREA data for October 2024, russia's revenues from crude oil exported by sea amounted to 210 million euros per day, 83% of the total volume of russian marine crude oil was transported by “shadow” tankers, while tankers owned or insured in countries that impose price restrictions accounted for 17% of the total value of russian oil exported in October. Under the sanctions, russia has begun to build up its own shadow fleet of outdated tankers, which has no 'ties' with the G7 and the EU and can transport oil in violation of price caps. russia disguises its shadow activities at sea under the 'convenient' flags of third countries, operates at sea without proper insurance from the international club of insurers, uses complex schemes to conceal the owners of the shadow fleet, uses various deceptive tactics to conceal the origin of its cargo, creates threats to environmental safety with large-scale economic costs for coastal countries due to the growing threat of oil spills, does not use pilots to navigate difficult areas, etc. russia's 'shadow fleet' continues to provide multibillion-dollar revenues for the kremlin bypassing sanctions, disguising its activities under the flags of third countries, using complex schemes to conceal owners, and poses significant environmental threats with significant economic costs to coastal countries and/or the international community due to the outdated and inadequate insurance of shadow fleet tankers. On December 03, 2024, USA imposed sanctions on the tanker.

During the period of the G7 and EU oil embargo and the price-cap policy on russian oil, the tanker has been involved in the export of russian oil mainly to India, making frequent calls to russian ports in the Black Sea. According to the USA-based advocacy group United Against Nuclear Iran (UANI), which monitors Iranian-related tanker traffic using satellite data, the vessel was involved in the transportation of Iranian oil and has switched to transporting russian oil since June 2022. 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. The international public organization Greenpeace refers to the tanker as a shadowy fleet of tankers transporting russian oil around the world and threatening the environment. Oil exports from russia are the most important source of income for the regime of the aggressor country to finance the war against Ukraine. From February 2022 to November 22, 2024, russia earned almost 546 billion euros in oil export revenues (69% of all fossil fuel export revenues). In 2023, about a third of all tax revenues in russia came from the sale of oil and gas. The tax on oil production collected by the russian federation in 2023 amounted to 8.9 trillion rubles, or 31% of total federal revenues. According to the CREA data for October 2024, russia's revenues from crude oil exported by sea amounted to 210 million euros per day, 83% of the total volume of russian marine crude oil was transported by shadow tankers, while tankers owned or insured in countries that impose price restrictions accounted for 17% of the total value of russian oil exported in October. Shadow fleet of russia continues to generate multibillion-dollar revenues for the kremlin bypassing sanctions, disguising its activities under the flags of third countries, using complex schemes to conceal owners, and poses significant environmental threats with significant economic costs to coastal countries and/or the international community due to the outdated and inadequate insurance of shadow fleet tankers.

During the period of the G7 and EU oil embargo and the price-cap policy on russian crude oil, the tanker is involved in the export of russian oil from russian ports in the Pacific region, in the Black Sea, mainly to China and Turkey. According to the USA-based human rights group United Against Nuclear Iran (UANI), which monitors Iranian-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. The international public organization Greenpeace refers to the tanker as a shadowy fleet of tankers transporting russian oil around the world and threatening the environment. Oil exports from russia are the most important source of income for the regime of the aggressor country to finance the war against Ukraine. From February 2022 to November 22, 2024, russia earned almost 546 billion euros in oil export revenues (69% of all fossil fuel export revenues). In 2023, about a third of all tax revenues in russia came from the sale of oil and gas. The tax on oil production collected by the russian federation in 2023 amounted to 8.9 trillion rubles, or 31% of total federal revenues. According to the CREA data for October 2024, russia's revenues from crude oil exported by sea amounted to 210 million euros per day, 83% of the total volume of russian marine crude oil was transported by shadow tankers, while tankers owned or insured in countries that impose price restrictions accounted for 17% of the total value of russian oil exported in October. Shadow fleet of russia continues to generate multibillion-dollar revenues for the kremlin bypassing sanctions, disguising its activities under the flags of third countries, using complex schemes to conceal owners, and poses significant environmental threats with significant economic costs to coastal countries and/or the international community due to the outdated and inadequate insurance of shadow fleet tankers.