March 2022 Iran Tanker Tracking

As part of the U.S. withdrawal from the JCPOA in 2018, the White House reimposed sanctions on Iranian oil and tankers to slash regime exports to zero. In response, Tehran farmed out the work to a parallel fleet of foreign vessels. This fleet, 177 strong and all foreign-flagged and foreign-owned, delivers Iranian oil thereby keeping the Islamic Republic in business. They form the “Ghost Armada,” a label that echoes the ways in which they evade tracking, scrutiny, and – most critically – sanctions. 

Four years after the “net zero” export goal was declared, this Ghost Armada transported a total of 889,821 barrels per day (bpd) to China in March 2022:

Country	March 2022 - Barrels Per Day (bpd)	February 2022 - Barrels Per Day (bpd)	January 2022 - Barrels Per Day (bpd)
China	889,821	746,201	851,759
Syria	126,412	82,143	68,496
UAE	0	23,576	0
Malaysia	0	20,320	0
Russia	0	0	0
Venezuela	0	0	0
Unknown	327,301	121,429	318,008
Total	1,343,525	993,669	1,239,263

View Iran Tanker Tracking

What can account for the Administration’s failure to enforce U.S. oil sanctions and blacklist these vessels?

Aside from President Biden’s apparent eagerness to secure a new JCPOA at almost any cost, it is reasonable to look at the technical challenge of navigating the intricacies of global shipping ownership. Unlike the individual designations of Iranian NITC and IRISL tankers, where ultimate responsibility lies clearly and narrowly with the regime, sanctioning individual ships from the Ghost Armada is not so simple.

For many ships, overlapping ownership layers are further obscured by multiple shell and front companies, plus the additional stratum of ‘beneficial ownerships,’ chartering, and ship management firms.  This presents a challenge to deciding who, or what, exactly might warrant sanctions. Which of the multiple stakeholders in a particular vessel are ultimately responsible for the decision to risk sanctions? Even the task of identifying the ‘ultimate owner’ – a reasonable target – is no mean feat.

Bad actors have long taken advantage of the opaque nature of ocean-borne commerce and its complications to mask identities and avoid sanctions. This was one of the key points outlined in the May 2020 sanctions advisory for the maritime industry. It stated:

Bad actors attempt to take advantage of this complexity through the use of complex business structures, including those involving shell companies and/or multiple levels of ownership and management, to disguise the ultimate beneficial owner of cargo or commodities in order to avoid sanctions or other enforcement action, among other reasons. Bad actors also may engage in a pattern of changes in the ownership or management of companies or in the International Safety Management Code (ISM) management companies used.

Put another way, if it is hard to identify who is behind a vessel, this should in itself raise a red flag. The Ghost Armada comprises majority of instances.

So, in our ongoing efforts to assist authorities, UANI has conducted investigations into the real owners of the Ghost Armada vessels.  Using official public records and other open-source data, our research to date has uncovered a web of front companies and facilitators that ultimately point back to Iran.

UANI will disclose our findings over the coming weeks. Today we start with four vessels linked to Vijaykumar Mishra and Mehdi Group.

Vijaykumar Mishra and Mehdi Group

In December 2021, UANI provided a list of the top ten vessels that transported the most Iranian oil during the year.  Three of those vessels are VIRGO (IMO: 9236250), VIGOR (IMO: 9262156), and HORNET (IMO: 9197844). UANI has determined that all three vessels, in addition to BERG 1 (IMO: 9262168), were managed by the Indian company Atlantic Navigation (OPC) Pvt Ltd at some point between November 2020 and today. 

According to the Indian Ministry of Corporate Affairs, the Director of Atlantic Navigation is Vijaykumar Mishra. Mr. Mishra is also the director of Vaniya Ship Management and 12 Degree Ship Management, two entities that were sanctioned on September 4, 2019, for acting for or on behalf of Mehdi Group subsidiaries Khadija Ship Management and Fourteen Star Ship Management. Mehdi Group is run by Ali Zaheer Mehdi, who was designated pursuant to E.O. 13224 for assisting in, sponsoring, or providing financial material, or technical support for, or financial or other services to or in support of, IRGC-QF official Rostam Ghasemi. Furthermore, Vaniya and Atlantic both share the same address in India at Unit 903, 9th Floor, Samarth Aishwarya, off KL, Walawalker Road, Andheri (W) Mumbai, 400053, India.

VIGOR

Since April 12, 2021, Atlantic Navigation, the company tied to the SDN-listed entity Vaniya, has been listed as the technical manager for the tanker VIGOR. Since then, VIGOR has transported over 9.5 million barrels of Iranian oil to China and is even presently laden with Iranian oil.

BERG 1

Between April 1, 2021, and September 1, 2021, Atlantic Navigation, was the technical manager for the vessel BERG 1. During this time, BERG 1 transported almost 4 million barrels of Iranian oil to China. Since then, the Indian-based company Everoon Ship Services OPC Pvt Ltd took over the technical management for the vessel. The websites for both Atlantic and Everoon are formatted very similarly.

HORNET

Between February 23, 2021, and June 11, 2021, Atlantic Navigation, was the technical manager for the vessel HORNET. During this time, HORNET transported approximately 2 million barrels of Iranian oil to China. Since then, the Indian-based company Gabbaro Ship Services OPC Pvt Ltd has taken over the technical management for HORNET. The address for Gabbaro Ship Services is Office 512, B Wing, 5th Floor, Samartha Aishwarya, KL, Walawalkar Road, Andheri (W), Mumbai, 400053, India.

Gabbaro’s address is the same address as Khadija Ship Management Private Limited, another entity sanctioned on September 4, 2019, for serving as a subsidiary of Mehdi Group.

VIRGO

Between November 25, 2020, and June 8, 2021, Atlantic Navigation served as the technical manager for the vessel VIRGO. During this time, VIRGO transported approximately 3.8 million barrels of Iranian oil to China. On June 8, 2021, the Indian-based company Marziya Shipping OPC Pvt Ltd took over the technical management for the vessel VIRGO.  As of June 8, 2021, VIRGO’s technical manager is Marziya Shipping OPC Pvt Ltd. Marziya is directed by Mohammad Ali (DIN: 09167875).

Although Atlantic Navigation is only listed as the current technical manager for one of the four vessels mentioned above, it is very relevant to our investigation of this sanctions evasion scheme. We have found that all of the new companies managing these vessels may still be tied to sanctioned entities, which is not surprising as we often see collaboration between entities on sanctions evasion and other illicit shipping schemes.

UANI will continue untangling the Ghost Armada’s ownership webs in our next post.