On March 13, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned (“designated” in OFAC language) Iran’s Minister of Petroleum, Mohsen Paknejad, who oversees the export of tens of billions of dollars’ worth of Iranian oil and has allocated billions of dollars’ worth of oil to Iran’s armed forces for export.
Announcing the new sanctions, Secretary of the Treasury Scott Bessent said, “The Iranian regime continues to use the proceeds from the nation’s vast oil resources to advance its narrow, alarming self-interests at the expense of the Iranian people.” He added, “Treasury will fight and disrupt any attempts by the regime to fund its destabilizing activities and further its dangerous agenda.”
Focus squarely on Iran, not Russia, so far
While the Trump administration is moving with focused precision against Iran’s oil trade, there is nothing but silence regarding Russian sanctions and possible use of frozen assets to help Ukraine. This subject is new to the Trump team as this sanctions program was expanded only after the Russian invasion of Ukraine in 2022, when Joe Biden was in the White House. The only movement to note on this subject, so far under the extremely tight-lipped Trump team, is that some Biden-era Russia sanctions mechanisms set in motion with extended phase-in periods were allowed to take effect and not/not cancelled by the incoming President. The primary but now-expired exemption allowed Russian banks to use U.S. payment systems for energy transactions.
As things stand now, without substantial movement on a peace deal, there is no loosening of sanctions on the horizon despite occasional rumors of U.S. – Russian discussions on “future economic cooperation.” But those rumors are more than enough to embolden some energy companies and even European pipeline operators to talk of brighter days, as well as conspiracy theorists worried that Trump’s team would foolishly give away the store to Putin. That last scenario should be downplayed as Europe’s cooperation would be needed to unfreeze and transfer many of the currently blocked Russian assets, and that is unlikely without Kyiv’s agreement, whatever Trump decides unilaterally.
When it comes to lifting sanctions, it should be recalled that the need for a full EU buy-in on frozen assets provides Brussels with perhaps the greatest leverage it will ever have versus a potential Trump “soft-on-Putin” policy in any Ukraine peace deal, which he is apparently seeking largely for personal legacy reasons, not to help a democratic Ukraine survive. That leverage should not be wasted.
More sanctions on Iran’s “shadow fleet”
Back to Iran, OFAC also designated several entities in multiple jurisdictions, including the People’s Republic of China (PRC) and India, for their ownership or operation of vessels that have delivered Iranian oil to the PRC, or lifted Iranian oil from storage in Dalian, PRC. These new sanctions apply further pressure on the Iranian “shadow fleet” and other cooperating vessels upon which Iran depends to deliver its oil to the PRC, advancing Washington’s commitment to reduce Iran’s oil exports to zero.
The March 13 actions were taken pursuant to Executive Order (E.O.) 13902, which target Iran’s petroleum and petrochemical sectors, and mark the third round of sanctions targeting Iranian oil sales since the President issued National Security Presidential Memorandum 2 on February 4, 2025, ordering a campaign of maximum pressure on Iran.
Iran’s Minister of Petroleum
Mohsen Paknejad serves as Iran’s Minister of Petroleum and has overseen the Ministry of Petroleum since his appointment in August 2024. Iran’s Minister of Petroleum oversees Iran’s National Iranian Oil Company (NIOC) and is responsible for all aspects of Iran’s oil industry, which generates tens of billions of dollars annually for the regime. Under his leadership, Iran’s Ministry of Petroleum has allocated billions of dollars’ worth of Iranian oil to the Iranian armed forces, including the Islamic Revolutionary Guard Corps and the Iranian Law Enforcement Forces, both critical instruments in the Iranian regime’s tools of oppression.
The Treasury Department estimates that some 200,000 barrels of Iranian crude oil are allocated to the Iranian armed forces daily to supplement their budget and the armed forces’ annual allocation of Iranian oil is set to increase. Recent budget estimates point to a four-fold dollar increase in oil allocations, exceeding $10 billion annually and totaling over 500,000 barrels per day. By the end of 2025, over half of Iran’s total oil revenues will be allocated to its armed forces. Paknejad is being designated pursuant to E.O. 13902 for operating in the petroleum sector of the Iranian economy.
Details of the shadow fleet’s oil transport operations
Iran’s Ministry of Petroleum and the Iranian armed forces rely on a vast shadow fleet of vessels to disguise oil shipments worth billions of dollars for delivery to the PRC.
Hong Kong-flagged PEACE HILL (IMO: 9288019) has transported millions of barrels of Iranian oil from the Changxhing Port in Dalian, PRC on behalf of the Iranian military. Since early 2024, San Marino-flagged SEASKY (IMO: 9237412) has transported tens of thousands of metric tons of fuel oil on behalf of NIOC to the PRC. Panama-flagged CORONA FUN (IMO: 9276573) has also transported Iranian oil and has used automatic identification system (AIS) manipulation to disguise its efforts to ship Iranian crude oil.
Hong Kong-based Hong Kong Heshun Transportation Trading Limited is the owner and operator of the PEACE HILL. Hong Kong-based Seasky Marine Co., Limited is the owner, operator, and manager of the SEASKY. Hong Kong-based Sun Science International Co., Limited is the owner, operator, and manager of the CORONA FUN.
Hong Kong Heshun Transportation Trading Limited, Seasky Marine Co., Limited, and Sun Science International Co., Limited are being designated pursuant to E.O. 13902 for operating in the petroleum sector of the Iranian economy. PEACE HILL is being identified pursuant to E.O. 13902 as blocked property in which Hong Kong Heshun Transportation Trading Limited has an interest. The SEASKY is being identified pursuant to E.O. 13902 as blocked property in which Seasky Marine Co., Limited has an interest. CORONA FUN is being identified pursuant to E.O. 13902 as blocked property in which Sun Science International Co., Limited has an interest.
Iran-flagged POLARIS 1 (IMO: 9272694) has transported tens of thousands of metric tons of NIOC fuel oil. The Cameroon-flagged LEXI (IMO: 9203277) has engaged in ship-to-ship transfers to transport millions of barrels of Iranian crude oil.
Seychelles-registered Fallon Shipping Company Limited and Bangladesh-based Aren Ship Management serve as the owner and technical manager of the POLARIS 1, respectively. Fallon Shipping Company Limited and Aren Ship Management are being designated pursuant to E.O. 13902 for operating in the petroleum sector of the Iranian economy. POLARIS 1 is being identified pursuant to E.O. 13902 as blocked property in which Fallon Shipping Company Limited has an interest. Suriname-based Sea Services Providers NV serves as the owner and operator of the LEXI. Sea Services Providers NV is being designated pursuant to E.O. 13902 for operating in the petroleum sector of the Iranian economy LEXI is being identified pursuant to E.O. 13902 as blocked property in which Sea Services Providers NV has an interest.
In addition, Comoros-flagged ITAUGUA (IMO: 9102277), Panama-flagged NESO (IMO: 9257149), Palau-flagged LYDYA N (IMO: 9153525) and BLUE GULF (IMO: 9328716), and Barbados-flagged SHANNON II (IMO: 9237797) have also shipped Iranian oil.
Liberia-registered Itaugua Services Inc serves as the owner and operator of the ITAUGUA. Marshall Islands-registered Neptune Marine Ltd and PRC-based Huaxia Trading Ltd serve as the owner and manager of the NESO, respectively. Seychelles-registered Turquoise Sea Marine Limited serves as the registered owner of the LYDYA N. Marshall Islands-based United Tankers Ltd and India-based Lake View Ship Management Private Limited serve as the owner and manager of the BLUE GULF, respectively. Marshall Islands-registered Celestite Maritime Inc and Sri Lanka-based Marine Solution Pvt Ltd serve as the registered owner and technical manager of the SHANNON II, respectively. These companies have been designated pursuant to E.O. 13902 for operating in the petroleum sector of the Iranian economy.
State Department Designations
The U.S. Department of State designated three entities and has identified three vessels as blocked property in which these entities have an interest.
Singapore-based Shipload Maritime PTE. Ltd., and Indonesia-based PT. Bintang Samudra Utama and PT. Gianira Adhinusa Senatama are being designated pursuant to E.O 13846 for having knowingly engaged in a significant transaction for the purchase, acquisition, sale, transport, or marketing of petroleum or petroleum products from Iran.
The Indonesia-flagged Malili (IMO: 9179921) is being identified pursuant to E.O. 13846 as property in which Shipload Maritime PTE. Ltd. has an interest. The Indonesia-flagged CELEBES (IMO: 8710730) is being identified pursuant to E.O. 13846 as property in PT. Bintang Samudra Utama has an interest. The Indonesia-flagged Marina Vision (IMO: 8106109) is being identified pursuant to E.O. 13846 as property in which PT. Gianira Adhinusa Senatama has an interest.
Sanctions implications: Designations will also impact non-U.S. citizens
As a result of the March 13 actions, all property and interests in property of the designated persons described above that are in the United States or in the possession or control of U.S. persons are blocked and must be reported to OFAC. In addition, any entities that are owned, directly or indirectly, individually or in total, 50 percent or more by one or more blocked persons are also blocked.
Unless authorized by a general or specific license issued by OFAC or exempt, U.S. sanctions generally prohibit all transactions by U.S. persons or within (or transiting) the United States that involve any property or interests in property of designated or otherwise blocked persons.
Violations of U.S. sanctions may result in the imposition of civil or criminal penalties on U.S. and foreign persons. OFAC may impose civil penalties for sanctions violations on a strict liability basis.
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