The sanctions target multiple entities across China, India, and the UAE. Notable among these is India-based Marshal Ship Management Private Limited, which provided crew members for several sanctioned vessels and allegedly assisted in falsifying shipping documents.
The investigation revealed a sophisticated operation involving multiple vessels and companies. The CH BILLION and STAR FOREST, recently designated as blocked property, have been actively involved in transporting Iranian oil. According to the OFAC, in August 2024, the CH BILLIONreceived over 600,000 barrels of Iranian crude oil through a ship-to-ship transfer, while the STAR FOREST has transported more than $100 million worth of oil to China.
The sanctions are part of a broader U.S. strategy implementing maximum economic pressure on Iran, aligned with a February 4 National Security Presidential Memorandum restoring President Trump’s “maximum pressure”, which is aimed at denying paths to nuclear weapons and countering Iran’s regional influence. However, these latest actions also follow a pattern of similar actions taken against Iran’s oil and gas sectors by the previous Biden Administration, which had ramped up following an Iran ballistic missile attack on Israel on October 1.
Under these sanctions, all property and interests of designated persons within U.S. jurisdiction are blocked and must be reported to OFAC. The measures also prohibit U.S. persons from engaging in transactions involving the designated entities and vessels.
This enforcement action highlights the ongoing cat-and-mouse game between international regulators and maritime operators attempting to circumvent sanctions through complex networks of front companies, vessel name changes, and falsified documentation.
