We have recently identified at least 28 vessels used as part of MODAFL’s illicit oil trade under the cover of Sahara Thunder.

22 of the vessels listed below were involved in sanction-evading or activity (STS, loitering and more).

Six of these vessels are already under U.S sanctions and are still transport oil on behalf of MODAFL (a sanctioned entity in itself).

Another worrisome information to highlight is that approximately 85% (24\28) of the vessels in Sahara Thunder’s fleet have changed their names in the past 2 years, with some of them doing so multiple times. This is a strong indication for a cover up attempt intended to hide the vessels’ involvement in sanction evasion and other illicit trade.

These vessels listed below are involved in the sanction evasion operations of the regime and MODAFL.

Based on the leaked materials, we have also identified about 13 different P&I clubs, based in multiple countries, which provide insurance policies to the vessels leased by Sahara Thunder.

By providing services to MODAFL, these legitimate P&I Clubs are in breach of US, EU and other global sanctions and are exposed to significant regulatory risk. Recently highlighted by the New York Times, P&I clubs and their compliance practices have long been under scrutiny as enablers of illicit Iranian oil trade.

It should be noted that at least 8 of those P&I Clubs listed below appeared recently in the leaked materials from Trilliance and are being used to insure both companies’ illicit trade.