Iranian sanctions 30 July 2025

On July 30, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced a significant expansion of sanctions targeting Iran’s petroleum sector, pursuant to Executive Order 13902. This latest action focuses on a sophisticated oil smuggling and maritime logistics network. The sanctions designate a wide array of entities and individuals across multiple jurisdictions—including the UAE, Turkey, Switzerland, Singapore, and Romania—for their roles in facilitating the illicit trade of Iranian and Russian oil.

Charles Patterson and Iqra Hussain have prepared the following advice on the sanctions:

"OFAC implemented a new Iranian sanctions package on July 30 2025, pursuant to Executive Order 13902.

The measures target a transnational oil smuggling and maritime logistics network controlled by Mohammad Hossein Shamkhani, the son of Ali Shamkhani, a senior adviser to the Supreme Leader of Iran.

The entities designated are alleged to have materially assisted, sponsored, or provided financial, material, or technological support for the Iranian petroleum sector, particularly in facilitating the illicit sale and shipment of Iranian and Russian oil and petroleum products. The network is said to operate through a vast fleet of vessels and a web of corporate structures designed to conceal the origins of the cargo, obscure beneficial ownership, and avoid detection by international regulators.

The following corporate entities were newly designated in July 2025:

Several shipping and vessel management firms headquartered in the United Arab Emirates were sanctioned, including Marvise SMC DMCC, Reel Shipping L.L.C, Armada Global Shipping DMCC, Koban Shipping L.L.C, Crios Shipping L.L.C, Fractal Marine DMCC, and The Zulu Ships Management and Operation and Sole Proprietorship L.L.C. These companies are alleged to be instrumental in operating and managing Shamkhani’s global fleet.

Other entities include Progwin Shipping SA, which are a Switzerland based shipping company formerly known as Fractal Shipping SA, managed by Mathieu Alain Michel Philippe, who is a French/ British dual citizen. Vessel management responsibilities were transferred to Westanker Denizcilik Ve Ticaret Limited Sirketi in Turkey and BPT Shipping Co L.L.C in the UAE. All the listed individuals and companies have also been designated.

In Singapore, Draco Buren Shipping PTE. Ltd. was identified as having managed up to 21 vessels on behalf of the network and have been designated.

Nest Wise Petroleum L.L.C, also based in the UAE, was also designated along with its Romanian and Singaporean subsidiaries. Max Energy Fuel Trading L.L.C, Carlington Petrochem FZCO, Etana Trading DMCC, and Teton Global Trading Limited, were also sanctioned. Other designated individuals include those who held positions in the sanctioned companies.

As a result of these actions, all property and interests in property of the designated individuals and entities within the US, or within the possession or control of US persons, are blocked. US persons are prohibited from engaging in transactions involving such property unless authorised by OFAC. Entities owned, directly or indirectly, by 50 percent or more by designated persons are also subject to blocking.

General licence R dated 30/07/25:

The US also issued this GL which highlights the following exemptions until 1 October 2025. The GL is specifically for US entities, and it allows them to engage in transactions ordinarily incident and necessary to a narrow set of safety-related and logistical activities involving some (but not all) of the vessels targeted on 30 July 2025.

Specifically, the following categories of activity are authorised:

• The safe docking, anchoring, and departure of designated vessels from any port that is not located in, or under the control of, the Islamic Republic of Iran or the Russian Federation.
• Activities aimed at ensuring the health and safety of the crew of the designated vessels.
• Conducting emergency repairs or implementing environmental protection or mitigation measures in respect of the designated vessels.
• The delivery and offloading of cargo that was loaded prior to 30 July 2025, provided such operations do not take place in ports within, or controlled by, Iran or the Russian Federation.

The licence expressly extends to ancillary maritime services necessary to carry out the authorised activities, including but not limited to vessel management, crewing, bunkering, piloting, insurance, registration, classification, and salvage operations. It does not permit the entry into new commercial contracts involving blocked persons or their property, unless directly related to the activities authorised above."

Further details can be found in the OFAC pages:

• Iran-related Designations; Issuance of Iran-related General License | Office of Foreign Assets Control
• Treasury Takes Massive Action Against High-Profile Iranian Network | U.S. Department of the Treasury

Whether you’re dealing with sanctions for the first time, or you require assistance with a sanctions dispute or investigation, Shearwater Law can help.

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