Client Alert: OFAC Continues its Focus on Iranian Oil Shadow Fleet and Global Network
On November 20, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced sanctions on a global network of individuals, entities, ships, and aircraft for their involvement with the Iranian regime. The alleged network was sanctioned pursuant to OFAC’s counterterrorism authority, as set forth in Executive Order (E.O.) 13224, as amended and pursuant to the Iranian Sanctions regime, E.O. 13846 and 13902.
In announcing the sanctions, OFAC noted it targeted six vessels of Iran’s shadow fleet bringing the total number of vessels sanctioned by the Trump Administration to over 170. OFAC’s action also focused on Iranian airline Mahan Air, which is alleged to have worked closely with the Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF) to arm and supply Iran-backed terrorist groups throughout the Middle East, including a key role in the Iranian regime’s efforts to arm the regime of former Syrian dictator Bashar al-Assad.
These designations reflect OFAC’s ongoing efforts to implement the Trump Administration’s “maximum pressure” strategy on Iran by focusing on its sale of black-market oil and its alleged continued support of terrorist groups in the Middle East. A key motivation for the Administration’s heightened focus on the shadow fleet is that Iran depends on it to transport petroleum products from domestic terminals to buyers in East and South Asia, often using reduced pricing to attract customers despite the inherent risk of being caught violating the existing sanctions regime. Notably, these most recent designations were truly global in scope, and included individuals, companies and vessels in Singapore, UAE, the Marshall Islands, India, Panama, and elsewhere. The designated entities include the vessels and their corporate owners, as well as service providers and purchasers of Iranian oil. For example, OFAC designated UAE-based Alsafeenah Althahabya Ship and Boats Spare Parts and Components Trading L.L.C., also known as Golden Argo Marine Services Co., which provides ship-to-ship services in the Persian Gulf. The announcement notes that ship-to-ship services can constitute a legitimate trade practice, but in this case the company provided services to Iran’s shadow fleet to obfuscate oil cargo origins and movements in violation of sanctions. Similarly, today’s actions caught up Germany-based BPT Berlin Petroleum Trading GmbH, a purchaser of Iranian oil.
These and the numerous other designated entities, individuals, vessels, and aircraft are now cut off from the U.S. financial system and effectively cut off from most reputable banks anywhere in the world. The Trump Administration has made clear it will continue its “maximum pressure” campaign against any and all businesses working with the Iranian oil sector or participating in Iran’s support for terrorist groups destabilizing the Middle East.