WikIran exposes the vessels and strategies used by Sepehr Energy Jahan, the trading arm of the Armed Forces General Staff (AFGS), to evade US Sanctions. Notably, these strategies include changing the names and flags of its ships.

In November 2023, Sepehr Energy Jahan (SEJ) came under international scrutiny after being designated by the US Department of the Treasury. Despite this, the Iranian company has demonstrated resilience in finding ways to circumvent sanctions. A recent investigation by WikIran uncovers compelling evidence of an extensive network involving at over 70 vessels engaged in the AFGS illicit oil and LNG trade, facilitated through SEJ. This revelation highlights the significant resources and sophistication employed by the AFGS to evade international sanctions and maintain their illegal energy operations.12 of those vessels are already under US sanctions, yet they continue to transport oil and gas (LNG) on behalf of the AFGS, a sanctioned entity itself. The following table lists these vessels:

A striking pattern emerges, with half of the sanctioned vessels bearing the flag of Guyana. This is relatively an unconventional choise, suggesting that the Guyanese flag may be gaining popularity as a flag of convenience, like the flags of Panama or Liberia. Moreover, half of the sanctioned vessels have changed their names since being sanctioned, with some undergoing multiple name changes. This pattern strongly suggests a deliberate cover-up attempt aimed at concealing these vessels' involvement in sanction evasion or other illegal trading activities. Such tactics are often employed to create a layer of obscurity, making it more challenging for authorities to track and intercept illicit shipments.

Some of the vessels used by Sepehr Energy Jahan for the AFGS were previously exposed by WikIran while being used by other sanctions-evading actors, and we can’t even say that we’re surprised. The following table lists these vessels:

Our investigation into the leaked documents also found that legitimate P&I Clubs provide services to the aforementioned vessels, potentially breaching US, EU and other global sanctions. The phenomenon is not new, as highlighted by a Bloomberg article, which exposed an American P&I club's unwitting role in insuring part of the Iranian export. These P&I clubs inadvertently become enablers for Iran's "shadow fleet", facilitating the AFGS's sanction-evading activities. Our investigation has identified at least three P&I clubs that are complicit in this illicit trade, as presented below:

To illustrate how the magic happens in practice, let's examine the case of the PRADA (IMO: 9213301). In July 2023, an email was sent by SEJ that presented the Q88 (Questionnaire 88) for the PRADA:

The Q88 provides a not-so-rare look into the Iranian Modus Operandi. The Cameroonian-flagged tanker has changed its name at least four times since 2019 and is insured by the Norwegian RO MARINE P&I Club. As of today, the PRADA sails with the Saint Kitts and Nevis flag, a well-known "comfort flag", and remains insured by the Norwegian RO Marine P&I club.

The three recent cargoes carried by the PRADA were reportedly Malaysian and Omani, with the last Ship-to-Ship (STS) process being carried out in April 2023 in Malaysia:

However, is it possible that the oil was actually Iranian, rebranded for plausible deniability? This would not be the first instance of "oil rebranding", as was previously reported by WikIran

Below is the full list of the leaked vessels that are involved in the sanction evasion operations of the AFGS and the regime. The list reveals the well-known tactics of "comfort flags" use and name changes. The accompanying graph shows the number of flags by country, with notable numbers including 19 Panamanian, 10 Guyanese and 6 Netherlands Antillean flagged vessels, making up almost half of the identified fleet:

List of Vessels involved in the sanction evasion operations of the AFGS: