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On January 23, 2026, the U.S. Department of the Treasury's Office of Foreign Assets Control ("OFAC") announced a new round of sanctions, intensifying pressure on the Iranian regime following its recent actions which led to the deaths of numerous protestors and a subsequent shutdown of internet access to the country. See Iran to consider lifting internet ban; state TV hacked | Reuters. The actions were taken pursuant to Executive Order ("E.O.") 13902, which targets Iran's petroleum and petrochemical sectors, and continue the sanctions campaign implemented under National Security Presidential Memorandum 2 ("NSPM‑2"), aimed at maximizing economic pressure on Iran.
Following the press release, OFAC has targeted nine vessels and their associated owners or management firms that comprise part of Iran's so‑called "shadow fleet" a network of ships used to transport Iranian oil and petroleum products in circumvention of U.S. sanctions. We previously discussed sweeping sanctions action targeting the fleet in August. See OFAC Targets Iranian Oil Network and Shadow Fleet in Sweeping Sanctions Action | Herbert Smith Freehills Kramer.
In the press report, OFAC alleges that these vessels collectively moved hundreds of millions of dollars in Iranian crude oil, fuel oil, LPG, condensate, and petrochemicals to foreign markets. Following the report, OFAC emphasized that these revenues, which it asserts rightfully belong to the Iranian people, are diverted to support regional terrorist proxies, weapons development, and domestic repression rather than the economic needs demanded by protestors. In remarks on this recent action, Treasury Secretary Scott Bessent described the Iranian regime as engaging in "a ritual of economic self‑immolation", amplified by the Administration's ongoing maximum pressure campaign. He reiterated that OFAC will continue tracking the regime's attempts to move funds stolen from the Iranian people into foreign banks.
Shadow Fleet Actors
OFAC's designations encompass a set of vessels and their respective ownership or management companies, many of which were established specifically for owning or operating individual ships.
Designated Vessels:
- SEA BIRD (IMO 9088536), for allegedly transporting hundreds of thousands of barrels of Iranian LPG to East Asia, Djibouti, and the UAE.
- AVON (IMO 9034705), for allegedly carrying multiple shipments of Iranian LPG to Bangladesh and Pakistan in 2025.
- AL DIAB II (IMO 9053816), for allegedly moving Iranian LPG to Pakistan and Somalia in 2025.
- CESARIA (IMO 9251602)for allegedly transporting millions of barrels of Iranian crude oil to East Asia since late 2025.
- LONGEVITY 7 (IMO 9240885) – for allegedly transporting Iranian condensate via ship‑to‑ship transfer and multiple cargoes of Iranian methanol; part of the shadow fleet since at least 2020.
- EASTERN HERO (IMO 9353905) for allegedly moving hundreds of thousands of barrels of Iranian high‑sulfur fuel oil since 2025.
- AQUA SPIRIT (IMO 9197727) for allegedly transporting Iranian petroleum products, including LPG, to Pakistan and other markets since 2025.
- CHIRON 5 (IMO 9306665) and KEEL (IMO 9176929) for allegedly carrying hundreds of thousands of barrels of Iranian naphtha in 2025.
Following the vessels above, OFAC also designated the following entities for operating in Iran's petroleum sector pursuant to E.O. 13902:
- Horizon Harvest Shipping LLC
- Aayat Ship Management Private Limited
- Black Stone Oil and Gas
- Galeran Service Corp
- Longevity Shipping Limited
- Odyssey Marine Inc.
- Benoil Shipping Inc.
- Trade Bridge Global Inc.
The above vessels were simultaneously identified as blocked property of these designated entities. For additional information on these vessels and the entities above please refer to this link.
Next Steps
This action underscores OFAC's continued focus on Iran related sanctions programs and secondary sanctions targeting non-U.S. actors involved in key sectors in Iran, notably the oil and gas sector. Companies in shipping, energy, insurance, and commodities trading should assess exposure to the designated entities and vessels.
OFAC Designation Implications
As with prior OFAC designations, all property and interests in property of the designated individuals and entities that are in the United States or in the possession or control of U.S. persons are blocked and must be reported to OFAC. Entities owned 50 percent or more by one or more blocked persons are also blocked under OFAC's 50% Rule.
All transactions by U.S. persons or within (or transiting) the United States that involve any property or interests in property of designated or blocked persons are prohibited unless authorized by a general or specific license issued by OFAC or exempt. These prohibitions include the making of any contribution or provision of funds, goods, or services by, to, or for the benefit of any blocked person and the receipt of any contribution or provision of funds, goods, or services from any such person.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
