On April 4, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control designated United Arab Emirates-based Oceanlink Maritime DMCC for facilitating the shipment of Iranian commodities on behalf of Iran’s military, including Iran’s Armed Forces General Staff (“AFGS”) and Ministry of Defense and Armed Forces Logistics (“MODAFL”). OFAC also sanctioned 13 vessels that Oceanlink manages, including the Hecate. According to OFAC, the Hecate recently received a ship-to-ship transfer of Iranian commodities valued at more than $100 million from the Dover, a previously-sanctioned tanker. OFAC reported that the transfer was made on March 25, 2024 on behalf of Iran’s Sepehr Energy Jahan Nama Pars, an entity that was sanctioned by OFAC in November 2023 for selling Iranian commodities for the AFGS and MODAFL.
The sanctions were imposed pursuant to Executive Order 13224, as amended, which targets terrorist groups and their supporters. As a result of these designations, all property and interests in property of the designated persons within the United States or within the possession or control of a U.S. person are blocked, and U.S. persons are generally prohibited from engaging in transactions involving a designated person. Entities owned 50 percent or more by one or more blocked persons are also blocked.