US OFAC designates 8 Iran shadow-fleet vessel-management firms and 9 vessels under EO 13902

Mechanism

Treasury framed the action as a response to the Iranian regime's crackdown on peaceful protestors and an internet shutdown concealing it, but the substance is a routine installment in OFAC's rolling EO 13902 shadow-fleet campaign — the same authority and NSPM-2 maximum-pressure framing used in the December 2025 (29-vessel Sakr) and October 2025 (~50-entity) actions. Eight single-purpose vessel-owning/management shells, each flagged in a convenience registry (Palau, Comoros, unknown), are designated for operating in Iran's petroleum sector:

• Horizon Harvest Shipping LLC (UAE) — SEA BIRD, LPG to East Asia,

Djibouti, UAE

• Aayat Ship Management Private Limited (India) — AVON, LPG to

Bangladesh, Pakistan

• Black Stone Oil and Gas (Oman) — AL DIAB II, LPG to Pakistan, Somalia
• Galeran Service Corp (Seychelles) — CESARIA, crude oil to East Asia
• Longevity Shipping Limited (Marshall Islands) — LONGEVITY 7,

condensate via ship-to-ship transfer; flagged as shadow-fleet since 2020

• Odyssey Marine Inc. (Marshall Islands) — EASTERN HERO, high-sulfur

fuel oil

• Benoil Shipping Inc (Liberia) — AQUA SPIRIT, LPG/petroleum products

to Pakistan

• Trade Bridge Global Inc. (Marshall Islands) — CHIRON 5 and KEEL,

naphtha

Concurrently, OFAC issued General License T authorizing limited safety, environmental, and cargo-offloading transactions involving the blocked vessels — the standard operational carve-out accompanying vessel designations to avoid stranding cargo/crew. Severity is set at 3, in line with the comparable December 2025 29-vessel action: eight shell operators and nine mid-size product/crude tankers represent incremental attrition on shadow-fleet shipping capacity rather than a systemically important buyer, bank, or state-owned refiner.

Downstream implications

• Extends the >180-vessel cumulative shadow-fleet sanctions count Treasury

has cited since January 2025, incrementally raising compliance and insurance costs across the Iran-to-Asia/South Asia product-tanker corridor.

• Confirms continued LPG/naphtha flows to Pakistan, Bangladesh and Somalia

via flag-of-convenience shells — a demand-side geography distinct from the China-heavy crude flows targeted in the October 2025 action.

• General License T's cargo-offloading carve-out signals OFAC is managing

stranded-vessel/cargo risk as the designated fleet grows, rather than seeking to trigger port congestion as a side effect.

Open questions

• Will the Marshall Islands and Liberia flag registries, which recur

across three consecutive OFAC shadow-fleet actions (Oct 2025, Dec 2025, Jan 2026), face any registry-level secondary pressure?

• Does this designation wave reach the Asian/South Asian end-buyers, or

does enforcement remain confined to the shipping layer as in prior rounds?