Saturday, September 7, 2019


If you take a close look at the latest list of Iranian-controlled crude oil tankers sanctioned by OFAC, for violations of international and US sanctions, the flags of two countries that offer Citizenship by Investment (CBI/CIP) programs show up. Literally, every time the US  places sanctions upon a group of vessels identified as Iran oil sanctions evaders, CBI issuers are found to be among them. This cannot be a coincidence.

The latest offenders:

(1) The BONITA QUEEN, formerly known as the KAMILA, vessel registration IMO 9105906, was registered in St Kitts & Nevis. It is associated with Khadija Ship Management Private Limited.

(2) the HAPPINESS,  formerly known as the TULARI, vessel registration IMO 9212905, was formerly registered in Malta. It has been linked to the National Iranian Tanker Company.

We have previously reported on several oil tankers sanctioned by OFAC, for carrying sanctioned Iranian crude oil, all registered in places like Dominica, St Kitts, and Malta. Obviously, the governments who permit registration of tankers know that the intended use of these vessels is sanctions evasion, but still, for the lucrative fees, permit these offending ships to carry their national registration, and fly their flags. Given that, thus far, the United States and the EU have not clamped down upon these countries, for allowing this illegal practice, they believe they are above the law, and immune from any regulatory or punitive law enforcement action

It has also been alleged that bribes and other illegal payments are tendered, and accepted, by government officials at these CBI jurisdictions, which are violations of the corruption laws of the US & UK, among others. Perhaps that avenue of law enforcement might cause the CBI republics to cease supporting Iran's global sanctions evasion program.

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