Sanctions & Complance
September 18, 2025

Oil Tanker Sanctions Screening has never mattered more: Complexity Behind a Simple Voyage

At first glance, shipping cargo from Point A to Point B seems straightforward. But beneath the surface, the maritime world is one of the most opaque, fragmented, and high-risk industries there is.

A Floating Web of Complexity

Ships are often:
  • Owned, flagged, operated, and chartered by entirely different entities—spanning multiple jurisdictions.
  • Registered under "flags of convenience" that obscure true nationality and regulatory oversight.
  • Owned by shell companies or nominee structures that make tracing accountability difficult.
  • Operated under complex charter chains that hide the real economic beneficiaries of trade.

In this environment, failing to detect links to sanctioned entities, jurisdictions, or deceptive practices—such as illicit ship-to-ship (STS) transfers, AIS manipulation, or flag-hopping—can expose the companies shipping the cargo to regulatory, financial, and reputational risk.

Due to rapidly shifting geopolitics, the stakes for maritime sanctions compliance have never been higher. Governments are expanding sanctions regimes targeting:

• Russian crude exports (price caps and export controls)

• Iranian and Venezuelan oil (longstanding embargoes)

• Entities and vessels aiding sanctioned regimes (secondary sanctions)

The U.S.A, EU, and UK have all expanded maritime sanctions in 2025, with measures targeting not only the cargo but also the financing, refining, and logistical support behind illicit shipments.

Compliance challenges are further complicated by the unprecedented growth of the shadow fleet—a network of tankers operating outside normal transparency standards to transport sanctioned oil.

Key 2025 facts from S&P Global Market Intelligence:

  • 3,154 tankers have transported Russian oil since Dec. 5, 2022 — almost 48% of the global in-service oil & product tanker fleet (≥27,000 DWT).
  • 940 vessels are in Tier 1 or Tier 2 (highest risk) categories — a 45% increase since May 2024.
  • The average shadow fleet vessel age is 20 years, with 60% of Tier 1 & 2 ships over 20 years old.
  • Panama is the leading flag for shadow fleet vessels (22%), followed by a growing number of false flag registrations (12%).
  • Tier 1 risk: 520 vessels (+92% YoY) directly sanctioned or owned by sanctioned entities.
  • Tier 2 risk: 420 vessels (+31% YoY) with opaque ownership or historical sanctioned ties.

Robust Vessel Sanctions Screening has become the first line of defence for:

  • Charterers
  • Cargo owners/shippers/receivers
  • Financial institutions
  • Insurers
  • Port and terminal operators

The Risks of Inadequate Screening - Key Mistakes in Tanker Vetting:

Chartering vessels linked to sanctioned entities
Example: Failing to identify ownership ties to a sanctioned company or individual.

Using ships involved in "dark activity"
Example: Employing vessels that disable AIS (Automatic Identification System) to hide illegal transshipments or routes.

Inadequate due diligence processes
Example: Relying on outdated or incomplete data during vetting, missing red flags related to past sanctions violations.

Consequences of These Mistakes:

  • Severe fines and enforcement actions (e.g., U.S. DOJ seizure, EU penalties)
  • Loss of insurance cover
  • Blacklisting by clients or major trading houses
  • Asset seizures and legal prosecution
  • Cargo detention or blacklisting of vessels
  • Commercial disruption and reputational harm for owners, charterers, and operators

How Our Sanctions & Dark Activity Screening Helps

Our platform mitigates risk against sanctioned entities or deceptive tankers that could slip through the cracks—helping you stay compliant, protect your reputation, and avoid costly missteps.

Shipvet’s sanctions screening service draws from a comprehensive set of data sources, updated daily, to provide accurate and timely compliance checks. The screening includes:

  • International and National Sanctions Lists

Cross-referencing vessels and related entities against up-to-date global and regional sanctions databases.

  • Vessel Ownership (Current & Historical)

Covers all levels of ownership including beneficial owners, operators, managers, and ultimate parent companies, helping identify indirect sanction exposure.

  • Port Call History

Monitors vessel port calls to or from sanctioned countries, enabling route-based compliance screening.

  • Flag State Monitoring

Tracks the current and historical flag registries of vessels to identify associations with high-risk or sanctioned flags.

  • Dark Activity Detection

Flags instances where a vessel’s AIS (Automatic Identification System) transmissions are turned off or missing, potentially indicating attempts to avoid detection.

  • Ship-to-Ship Transfers (STS)

Identifies STS activities involving sanctioned or high-risk vessels, including location and counterpart analysis.

What happens when you don’t screen properly?

Let’s look at real-world enforcement cases that underscore the true cost of compliance failures:

1. Using Vessels Linked to Sanctioned Entities
Case Study: Tinos I (Vitol Charter) High-Risk Charter from Sanctioned Iranian Network

In July 2025 Lloyds’s List reported the case of Vitol seeking the arrest of VLGC Tinos I after it was detained on its maiden voyage to Houston in June 2024 and subsequently sanctioned in April 2025 due to its connection with Iranian businessman Seyed Asadoollah Emamjomeh. Vitol chartered the vessel in April 2024 and terminated their TC contract 11 months later without ever having loaded any cargo. Vitol stated it “did not have reason” to believe the vessel was sanctions-exposed at that time.

Timeline of Events
  • April 2024: Vitol chartered Tinos I, a brand-new VLGC, from Dubai-based Pearl Petrochemical FZE (linked to Iranian businessman Seyed Asadoollah Emamjomeh).
  • June 2024: Vessel arrived in Houston, but offloading was delayed due to regulatory concerns.
  • April 22, 2025: OFAC designated Tinos I, Pearl Petrochemical FZE, and Emamjomeh under sanctions for involvement in funding Iran via LPG exports.
  • May 20, 2025: OFAC issued a General License for port safety, crew support, and conditional vessel sale (with proceeds held in blocked accounts).
  • July 2025: Vitol filed suit in U.S. District Court (Southern District of Texas) to terminate the charter and arrest the vessel.
Key Mistakes

Inadequate ownership due diligence, late response to red flags, exposure to U.S. jurisdiction by sailing to Houston.

Outcome

Vessel sanctioned, stuck in port, proceeds frozen, Vitol in legal dispute to unwind charter

Lessons Learned

Even newbuilds need full ownership vetting; act at the first sign of risk.

2. Insufficient Scrutiny of Counterparties and Trade Finance
Case Study: Arina & Nostos - U.S. Seizure of Suspected Iranian Oil from Greek Tankers

U.S. authorities investigated Nostos for facilitating transactions linked to Iranian oil exports using complex financial structures and intermediaries. This case highlights the risks of enabling sanctioned trade through indirect, non-shipping channels—underscoring the need for robust counterparty and trade finance due diligence.

Timeline of Events
  • Nov 2020: Stark I (NITC, under sanctions) loaded Iranian crude at Kharg Island and transferred 733,876 barrels via STS to Arina.
  • Aug 2021: Arina transferred ~220,800 barrels to Nostos (Eurotankers) off Cyprus.
  • Late 2021–Early 2022: U.S. authorities directed:
    • Nostos to Houston (discharged Nov 2021)
    • Arina to Bahamas (discharged Jan 2022)
Key Mistakes

Trusted false documents, failed to flag multiple risky transfers, missed identity-altering tactics.

Outcome

$38M in oil seized; vessels not sanctioned but put under close watch.

Lessons Learned

Independently verify cargo origin; monitor STS near high-risk areas; beware vessel identity manipulation.

3. Inadequate Oversight of Cargo Origin and Transfers
Case Study: Maersk Magellan – Iranian Oil & Sanctions Risk

While Maersk claimed unawareness, the vessel was implicated in STS operations involving sanctioned Iranian oil. Even reputable vessels can unknowingly become involved in illicit supply chains if oversight is weak.

Timeline of Events
  • 2022: Maersk Magellan allegedly involved in a ship-to-ship (STS) transfer with a sanctioned vessel suspected of carrying Iranian crude.
  • The STS operation took place near Singapore, a known hotspot for covert transfers.
  • Vessel carried crude to China, where final discharge occurred.
  • U.S.-based watchdog United Against Nuclear Iran (UANI) flagged the activity publicly.
Key Mistakes

Weak oversight of STS operations, insufficient monitoring of AIS gaps and suspicious routing.

Outcome

No sanctions, but public exposure and increased scrutiny of vetting processes.

Lessons Learned

Reputation isn’t protection; STS in hotspots needs rigorous vetting and cargo origin checks.

4. Overlooking Deceptive Shipping Practices ("Dark Activity")
Case Study: Suez Rajan – Landmark U.S. Seizure of Sanctioned Iranian Oil

Caught carrying Iranian crude oil, despite attempts to conceal its origin through ship-to-ship (STS) transfers and AIS signal manipulation. This highlights the need to monitor voyage history and STS activity patterns.

Timeline of Events
  • Feb 2022: Watchdog group UANI flagged Suez Rajan (operated by Empire Navigation) for allegedly carrying Iranian crude, after an STS transfer near Singapore.
  • Vessel reportedly loaded ~1 million barrels from a sanctioned ship operating covertly.
  • Suez Rajan remained anchored off Malaysia for months amid mounting scrutiny.
  • Aug 2023: U.S. DOJ confirmed it had seized the Iranian cargo and redirected it to Texas, despite Iranian threats of retaliation.
Key Mistakes

Accepted cargo without confirming origin, delayed response despite watchdog flags, documentation discrepancies.

Outcome

U.S. seized 1M barrels of oil; operator avoided penalties by cooperating.

Lessons Learned

AIS and satellite tracking are essential; reputational damage can hit before legal action.

Overall Patterns:

  • Failures came from ownership screening gaps, cargo origin misrepresentation, STS oversight failures, and reactive—not proactive—compliance.
  • Consequences included seizures, vessel immobilization, reputational harm, and costly legal action.

Conclusion: Sanctions Risk Is Real—And Rising

As global sanctions regimes grow broader, deeper, and more aggressively enforced, the maritime sector faces unprecedented scrutiny. The case studies above show a clear pattern: even well-established players can become entangled in sanctions violations through oversight, insufficient due diligence, or reliance on incomplete data.

In today’s compliance landscape, ignorance is not a defence—and intent is not a requirement for liability. A single weak link in vetting can trigger regulatory investigations, asset seizures, lost cargoes, reputational damage, and millions in fines.

Robust vessel sanctions screening is no longer optional—it’s essential.

Shipvet Sanctions Screening – Your Frontline Defence Against Maritime Risk.
Why Choose Shipvet?

Because in today’s world, due diligence isn’t optional—it’s mission-critical. Shipvet gives you the clarity and confidence to act decisively, mitigate risk, and maintain a strong compliance posture.