The transactions are often handled by Gulf-based middlemen, thereby shielding the identity of the Iranian sellers from the purchasers. Much of the fuel oil is shipped to the United Arab Emirates, through a variety of covert schemes, including:
(1) Ship-to-ship transfers in the Persian Gulf; the oil is then delivered to the UAE for sale.
(2) Discharging the oil at obscure Gulf ports.
(3) Direct shipment from Iran to the UAE, during which journey the vessel operator disengages its transponder/GPS location devices, so that no monitoring of the passage is possible.
Records of regular shipments, by Iranian-owned tankers, and storage in Malaysia and Singapore, indicate that Asia has become a favoured destination for the sanctioned product, which is later sold as being of Iraqi origin.
Should any of your bank clients be engaged in this type of transaction, you will want to ensure that your payments are not ultimately going to Iranian-controlled financial institutions in the Middle or Far East. considering the proliferation of sanctions targeting Iran's petrochemical industry, you want to be very careful here.
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