Sea vessels

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 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 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. On October 11, 2024, the USA imposed sanctions on the tanker as a property in which Celia Armas 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 vessel is involved in schemes to steal Ukrainian grain from the TOT of Crimea (Ukraine). In 2024, the vessel makes frequent calls to the ports of the TOT of Ukraine, uses the practice of turning off the AIS signal and conducting so-called 'dark' activities in the Azov and Black Seas.

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 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 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 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 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.

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 russian ports to third countries, and resorts to the practice of turning off the AIS signal, conducting so-called 'dark activities' at sea. The owner, manager and commercial manager of the tanker is an unknown company Tagabo Maritime Corp. (Seychelles), and the ISM manager is the Indian company Pinaka Ship Management. The fleet of the shipowner and the commercial manager of the vessel consists only of the tanker 'NANDA DEVI'. The vessel is certified by the Indian regulator Indian Register of Shipping (IACS). The tanker 'NANDA DEVI' is affiliated with the Indian company Gatik Ship Management, one of the leading operators of the so-called 'shadow' fleet involved in the transportation of russian crude oil under Western sanctions, and the company Orion Ship Management LLP, which is related to Gatik, which in 2023, together with Caishan Ship Management, Plutos Ship Management, Gaurik Ship Management LLP, Geras Ship Management, Girik Ship Management, Galena Ship Management, Nautilus Shipping (India), Ark Seakonnect Shipmanagment LLC, Zidan Ship Management, was involved in a scheme to 'juggle' vessels operated by Gatik Ship Management to avoid sanctions. Gatik Ship Management and Orion Ship Management were the previous managers of the tanker 'NANDA DEVI'. Tankers operated/managed by India's Gatik Ship Management continue to be used by related companies and call at russian ports. As sanctions are being imposed, russia uses a scheme of "juggling" ships between related companies to conceal oil exports outside the price cap and other restrictions, as well as to hide the real owners of ships, and to ensure unimpeded transportation of fossil fuels by a 'shadow' fleet of obsolete oil tankers, creates new companies for these purposes (in the UAE, Hong Kong, India, Turkey, Mauritius, Seychelles, and other jurisdictions) with non-transparent organizational and ownership structures. In order to implement this scheme, technical/commercial management and ship owners are constantly changing, and vessels are renamed with a change of flag, MMSI, call-sign, including for sanctioned vessels. Shadow fleet vessels operate under “convenient flags”, which allows them to conceal their true origin and avoid control by international organizations and insurance companies. Almost all vessels that are involved in the transportation of russian oil by the shadow fleet since 2022 have been certified by the Indian regulator Indian Register of Shipping (IACS). The certification of shadow fleet vessels allows the shipowner/operator to insure the vessels, which, in turn, allows the vessels to enter ports and pass through various specific sea routes (straits, canals, etc.). The 'shadow' fleet, transporting huge volumes of crude oil through heavily trafficked routes through narrow straits close to the coastline, without proper P&I insurance, with automatic identification systems disabled, threatens an environmental disaster with significant economic costs to be borne by the affected coastal countries and/or the international community. The recent incidents off Malaysia only underscore the need for swift action to curb the potentially devastating impact of the growing 'shadow fleet'. 'Shadow' tankers have already been involved in 50 incidents from the Danish Straits all the way to Malaysia since russia's full-scale invasion of Ukraine. According to CREA, from January to August 2024, the number of shadow tankers crossing the Danish Straits in Europe increased by 277% compared to the same period in 2022, with 64% of the 46 million tons of russian marine oil transported through the Danish Straits being transported by shadow tankers. In the same period, the number of shadow tankers in the Straits of Dover and Gibraltar increased by 355% compared to 2022, transporting 67% of the 37 million tons of oil through the straits. The Suez Canal experienced a staggering 649% increase in shadow tanker traffic, with 69% of the 52 million tons of russian crude oil passing through it being transported by these vessels. Thus, the 'shadow fleet' of the russian federation 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 threats to environmental safety with significant economic costs for coastal countries and/or the international community due to the outdated and inadequate insurance of shadow fleet tankers.

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.