July 2024 Iran Tanker Tracker

For more than six years, through dozens of private letters and a lot of public exposure, UANI has led the campaign to compel Panama to stop flagging vessels involved in transporting Iran’s sanctioned oil.  Evidently, our efforts have begun to bear fruit: since January 2024, the Maritime Authority of Panama (AMP) has deleted some 109 vessels from its registry.

But others are taking up the slack. Chief among them is the Cook Islands – a tiny (pop. 15,000) self-governing South Pacific Island nation in 'free association' with New Zealand – which is today the fastest growing flag registry.  Since the start of 2024, the Cook Islands has added some 35 “Ghost Armada” vessels – tankers identified by UANI as having transported Iranian oil – to its registry.  Given four years’ worth of courteous mutual correspondence between UANI and Maritime Cook Islands, in which the authority has generally acknowledged UANI’s warnings regarding its flagging of vessels of concern, this is a disturbing trend (more analysis below).

As all flaggers understand only too well, particularly those providing “flags of convenience,” this service is an indispensable part of Iran’s oil trade, helping Tehran continue to export in excess of 1.9 million barrels per day in the latest month: 

*Figures to be updated over the following weeks

The Cook Islands and the Flagging of Iranian Oil-carrying Tankers

On July 25, Lloyd’s List reported that the Cook Islands was the fastest-growing registry in 2024, “flagging more tankers than registries that are 30 times its size as it targets Russia-trading ships.” Taking into account only those vessels transporting sanctioned oil from Iran, UANI analysis shows that the Cook Islands has also flagged more “Ghost Armada” ships any other flag state over the same period.

In the first seven months of 2024 then, the Cook Islands added 35 vessels to its registry that are part of the Ghost Armada. This is significantly more than other registries, underlining the Cook Islands’ emerging role in the global shipping industry for these high-risk trades. 

The Cook Islands’ ability to attract a large number of these vessels hints at a growing reputation as a flag of convenience for ship owners looking to navigate sanctions. These vessels, often older and anonymously owned, use deceptive practices to evade detection and continue trading in sanctioned oil markets. 

In 2024, the Cook Islands assured UANI, “this Administration will take in due account the OFAC list published by the US government and the Cook Islands will take appropriate actions for any vessels, owners, or managers that might be added to such list.” This is a welcome policy. However, flag registries have a bigger obligation to monitor and delete vessels transporting Iranian oil, even if OFAC does not yet sanction them. Flag states are responsible for ensuring that vessels flying their flag comply with international regulations and sanctions. Failure to do so puts registries at risk of sanctions themselves. By allowing these vessels to operate under their flag, the Cook Islands potentially facilitates illegal activities, undermining efforts to enforce sanctions on Iran.

To uphold international standards and avoid complicity in sanctions evasion, all flag registries ought to proactively monitor and deregister vessels engaged in the illicit transport of Iranian oil. This is important not only for maintaining its own regulatory compliance but also for supporting the integrity of sanctions designed to curb Iran's unlawful oil trade.

To reiterate, Panama, historically the biggest flagger of colluding tankers helping the Islamic Republic, has in short order removed a significant number of these vessels from its registry, indicating a shift in flagging practices. 

This welcome swing highlights the effectiveness of sustained, multi-year efforts to publicize this issue, with other concerned parties also galvanized to add their voices.  As much as public and private pressure clearly played a role, we trust Panama also took into account the ethical imperative behind UANI’s simple notion: the maritime industry should stop helping Iran export oil. Now it’s over to the Cook Islands to embrace the same idea.