The “shadow fleet” is a loose network of commercial tankers, ship managers and intermediaries that use deception to hide Iranian-origin oil, refined fuels and petrochemicals as they move cargoes to buyers. Operators obscure origin through practices such as reflagging vessels, false or “ghost” ownership and management, false or altered ship/identity records, frequent ship-to-ship transfers and transshipment, turning off or manipulating AIS (‘dark’ activity), falsifying cargo and port documentation, and routing via third-country intermediaries and brokers to mask ties to Iran.
State-designated (from the Department of State Fact Sheet, Feb 6, 2026): Entities — ALL WIN SHIPPING MANAGEMENT LIMITED (commercial manager of VICSCENE); MANARAT ALKHALEEJ MARINE SERVICES FZE (UAE commercial manager of OCEAN GUARDIAN and AL SAFA); QINGDAO OCEAN KIMO SHIP MANAGEMENT CO LTD (commercial manager of BENLAI); VICENS MARINE CO (Marshall Islands–based owner/manager of AQUA LIVE); SHANGHAI QIZHANG SHIP MANAGEMENT CO., LTD (commercial manager of petrochemical carriers including YONGHENG OCEAN); ELYSIAN HORIZON CORP (Seychelles owner/manager of ZEVS); FLUXUS MARINE INC (Kazakhstan commercial manager of VETER); MPHASIS MARINE SOLUTIONS FZE (UAE commercial manager of RAYYAN GAS and GAZ CRYSTAL); MHK SHIPPING CORP (Türkiye commercial manager of FORTUNE GAS and GAS RIVER); MARS OCEANWAY INC (Türkiye owner/manager of WHITE SHARK); ELEVATE MARINE MANAGEMENT PRIVATE LIMITED (India commercial manager of BENEDICT); DIAKO IC VE DIS TICARET ANONIM SIRKETI (Türkiye petrochemical trader); STAREX DIS TICARET KIMYA ANONIM SIRKETI (Türkiye petrochemical trader); BAKHT AL AZHAR TRADING L.L.C (UAE exporter/trader); AMON KIMYA VE MAKINA SANAYI VE TICARET L. (Türkiye importer of Iranian ammonia). Individuals — AKASH ANANT SHINDE (Indian national; director of ELEVATE) and MEHMET OZSUREN (Turkish national; manager and majority shareholder of AMON KIMYA). Vessels (identified as blocked property) — VICSCENE (IMO 9290775, Barbados-flagged); OCEAN GUARDIAN (IMO 9267948, Panama-flagged); AL SAFA (IMO 9222649, Panama-flagged); BENLAI (IMO 9312494, Barbados-flagged); AQUA LIVE (IMO 9282792, Aruba false-flagged); YONGHENG OCEAN (IMO 9234472, Barbados-flagged); ZEVS (IMO 9168946, Cameroon-flagged); VETER (IMO 9233739, Cameroon-flagged); RAYYAN GAS (IMO 9133109, Palau-flagged); GAZ CRYSTAL (IMO 9318618, Panama-flagged); FORTUNE GAS (IMO 9471123, Panama-flagged); GAS RIVER (IMO 9369760, Panama-flagged); WHITE SHARK (IMO 9155626, San Marino-flagged); BENEDICT (IMO 9293155, Cameroon-flagged).
E.O. 13846 ("Reimposing Certain Sanctions With Respect to Iran") provides the President authority—chiefly under the International Emergency Economic Powers Act (IEEPA) and related statutes—to reimpose and implement secondary sanctions on persons who knowingly engage in significant transactions involving Irans petroleum, petroleum products, petrochemicals, or other activities specified in the order; to block (freeze) property and interests of designated persons; and to prohibit U.S. persons from dealing with designated/blocklisted parties absent OFAC authorization. The order establishes the legal basis used by State to designate persons and to refer reporting and blocking to Treasury/OFAC for implementation and enforcement.
Sanctions generally make doing business with designated vessels and their managers legally risky and often effectively impossible for U.S. persons and many international firms: U.S. persons must block and report any property or interest in the designated vessels/companies; banks, insurers and flag/state authorities risk secondary sanctions or being cut off from U.S. financial markets if they provide services (financing, insurance, brokering) to designated parties; ports and service providers face legal exposure if they facilitate transactions involving blocked property without OFAC authorization; and companies may be required to deny port entry, insurance coverage, or finance for those vessels. Practical consequences include de‑risking by global insurers and banks, refusal of port services, and removal from commercial insurance pools.
Under E.O. 13846 and implementing OFAC rules, designated persons and property are ‘‘blocked’’—their U.S.-located assets must be frozen and U.S. persons are prohibited from dealing with them absent an OFAC license. Penalties for violations include civil fines (often large) and criminal penalties for willful violations; OFAC enforces on a strict-liability civil basis and may pursue criminal referrals for egregious conduct. Designated vessels identified as ‘‘property in which a designated person has an interest’’ are similarly blocked; U.S. transactions involving those vessels (ownership transfers, finance, insurance, port calls involving U.S. persons) are prohibited without authorization.
The State Department identifies targets (policy/foreign‑policy designations) and explains reasons and diplomatic intent; Treasury (OFAC) implements blocking, adds names to the Specially Designated Nationals (SDN) list, issues OFAC licensing guidance, and pursues enforcement (civil/criminal penalties). State’s designations are made pursuant to E.O. 13846 and then Treasury/OFAC publishes press releases and regulatory guidance to operationalize the measures—so State sets policy and identifies targets while Treasury enforces and provides licensing/reporting channels.
The State Department statement and Treasury materials tie the designated network’s shipments and transactions to revenue streams for the Iranian regime, saying those proceeds fund regional proxies, weapons programs and domestic repression. The State Fact Sheet cites vessel movements that “transported Iranian‑origin” crude, LPG, ammonia and petrochemicals on multiple occasions (with dates/IMO numbers and buyer regions) as the factual basis; Treasury/OFAC releases and prior enforcement actions document patterns of shipments, brokerage and payments that Treasury says produced ‘‘hundreds of millions’’ in revenue used by Iran. (Some underlying evidence—commercial bills of lading, AIS/ship movement data, transactional records—are cited in Treasury/State statements and OFAC fact sheets; full underlying intelligence/financial evidence is not publicly released.)