The 2025 maximum pressure escalation.
On 4 February 2025, U.S. National Security Presidential Memorandum 2 ordered a “campaign of maximum pressure” on Iran, including driving Iran’s export of oil to zero and cutting off revenue streams that fund the development of its nuclear program. OFAC subsequently imposed multiple rounds of sanctions targeting Iran’s “shadow fleet” — the entities and vessels responsible for shipping millions of barrels of Iranian oil around the world.
Using Sayari Graph to map vessel ownership, Sayari analysts revealed common ultimate beneficial ownership across multiple sanctioned entities and vessels in this network — as well as additional unsanctioned entities and vessels. Due to their proximity to confirmed Iranian shadow fleet operators, additional due diligence on these commonly-owned actors is vital to law enforcement’s ability to identify and prevent further shadow fleet activity.
How the shadow fleet operates.
The Iranian oil smuggling shadow fleet is characterized by deceptive practices designed to evade sanctions and fund illicit activities. Vessels are typically older, frequently change flags, obfuscate true ownership, and employ a range of evasion tactics. Key among these is Automatic Identification System (AIS) manipulation — vessels “going dark” to avoid detection or spoofing their locations — as well as illicit ship-to-ship (STS) transfers at sea designed to obscure the origin of oil.
Compounding oversight challenges are the use of false documentation and intricate, opaque ownership structures. The ramifications extend beyond simply undermining global sanctions regimes: shadow fleet activity funds destabilizing regional actors and poses significant environmental and safety risks due to unregulated maritime operations.
Unveiling a sanctioned network.
On 20 March 2025, OFAC designated 19 entities and vessels responsible for shipping millions of barrels of Iranian oil, including the Panama-flagged Viola (IMO: 9254915) and its owner Sea Breeze Shipping Inc. Roughly a month later, OFAC designated 12 additional entities and vessels — including the Panamanian-flagged RANI (IMO: 9250907) and Nyantara (IMO: 9242120), and their respective owners Starboard Shipping Inc. and Civic Capital Shipping Inc.
Records collected from Panamanian corporate ownership data reveal that all three sanctioned companies share the same personnel: president Muhammad Irfan, treasurer Rogelio Manuel Aguilar Bethancourt, and secretary Hector Varela De León. Bethancourt and De León are listed as the founders of all three. All were sanctioned for operating in the petroleum sector of the Iranian economy through their respective vessels conducting AIS manipulation and STS transfers to obfuscate Iran’s petroleum shipments.
Bethancourt and De León’s broader network.
Though Irfan appears connected only to Sea Breeze, Starboard, and Civic Capital, Bethancourt and De León share control of dozens of other companies in Panama — many of which also own vessels. Of these 40+ companies, at least four currently or formerly own vessels sanctioned for facilitating the shipment of Iranian commodities on behalf of Iran’s military, government, and military-backed civilian entities:
- Baxter (IMO: 9282522) — sanctioned 4 April 2024 for facilitating shipments on behalf of Iran’s Armed Forces General Staff (AFGS) and Ministry of Defense and Armed Forces Logistics (MODAFL).
- Dancy Dynamic (IMO: 9158161) — sanctioned 25 April 2024 for shipping commodities on behalf of Sahara Thunder, the main front company for MODAFL’s commercial activities.
- Mirova Dynamic (IMO: 9237618, a.k.a. Star Line) — sanctioned 18 July 2024 for transporting illicit shipments worth tens of millions of dollars in support of Iran’s Islamic Revolutionary Guard Corps – Qods Force (IRGC-QF).
- Tulip BZ (IMO: 9014420, previously St. Cudi, most recently Sarah) — sanctioned 28 April 2025 for transporting petroleum products on behalf of the IRGC and in support of the Houthis.
Beyond the sanctioned vessels, Bethancourt and De León together control at least 40 additional companies and 20 additional vessels likely deserving additional scrutiny due to their proximity to confirmed Iranian shadow fleet operators.
The Alora case.
The Barbados-flagged Alora is one such unsanctioned vessel deserving additional scrutiny. It has been owned by multiple Bethancourt and De León companies and has transported oil products at least since 2023. Between late 2024 and early 2025, the Alora’s ownership changed from ASUS MARINE SERVICES INC. to HARBOR HIGHT MARINE INC. — two UAE-based companies founded and controlled by Bethancourt and De León. Despite the direct change in ownership, the ultimate control of the vessel remained the same — possibly an attempt at obfuscation.
Most significantly: 22 trade records collected by Sayari report the Alora as the vehicle of transport, twelve of which report the vessel delivering over a million barrels of alkylate from India to the United States from March 2023 to July 2024. Alkylate — a high-quality form of gasoline primarily used in aviation — has previously been observed being smuggled by sanctioned Iranian oil tankers. AIS manipulation and STS transfers already used by Bethancourt and De León’s sanctioned vessels would obscure the ultimate source of the alkylate if it were smuggled from Iran.
These findings were only made possible by combining datapoints extracted from U.S. sanctions, vessel ownership, Panamanian corporate, and U.S. trade data — enabling analysts to paint a more complete picture of an interconnected network. Sayari’s Commercial World Model covers 10.6B+ primary-source records across 250+ jurisdictions. Disrupting shadow fleet activities requires aggregation and resolution of global public data sources at this scale, paired with rigorous network analysis. Sayari Graph delivers both.