The International Convention for the Safety of Life at Sea (SOLAS) requires the continual operation of an Automatic Identification System (AIS) on all ships that undertake international voyages and have a volume greater than 300 gross tons. Both Iran and the U.S. are parties to SOLAS, along with 162 other states, yet Iranian oil tankers have begun to mask their location for several days at a time by turning off their AIS transponders. This is likely a dry run for the evasion of U.S. sanctions on Iran’s oil exports, which will take effect on November 4.
Tehran previously directed the captains in its tanker fleet to switch off their transponders to frustrate enforcement of the U.S. and European oil sanctions that were in effect prior to the conclusion of the 2015 nuclear deal with Iran.
However, there are substantial risks associated with concealing the position of a ship from other vessels. In January of this year, the Iranian tanker Sanchi burned and sank in the East China Sea after colliding with a freight ship, killing all 32 members of the tanker’s crew. The tanker had not broadcast an AIS signal for more than 9 hours prior to the collision.
Bloomberg reports that ten Iranian-owned tankers recently failed to broadcast their location for several days. The Tanker Trackers analysis group employed satellite imagery to show that two of the ten invisible tankers remained, as of late Monday, at their previously broadcast location, near the main Iranian export terminal at Kharg Island in the Persian Gulf. However, the imagery shows that a third tanker has departed.
Using data from Marine Traffic, FDD determined that three of those ten tankers – the Happiness I, Huge, and Sea Cliff – resumed AIS broadcasts on Wednesday after transiting from the Persian Gulf into the Arabian Sea.
Tanker Trackers previously documented how six foreign-owned tankers carrying Iranian crude have routinely switched off their AIS transponders when approaching Syrian ports. The group then employed satellite imagery to confirm the tankers’ arrival. These deliveries almost certainly violate Executive Order 13582(2011), which prohibits “financial, material, and technological support” to the government of Syria. Pursuant to that order, the Treasury Department imposed sanctions on Syria’s national oil companies as well as its ports and ports directorate.
Earlier this month, Treasury sanctioned a series of front companies and related individuals for working with Damascus to import fuel. Despite U.S. action, Iran shipped 30,000-60,000 barrels of oil per day to Syria in August, with an estimated value of $75-$150 million according to Tanker Trackers.
With sanctions on Iranian oil exports set to return in less than six weeks, the U.S. government should explore ways to hold Tehran accountable for its dangerous and unlawful violation of maritime safety standards. The firms transporting Iranian crude will be subject to sanctions. So will firms providing private insurance. The U.S. government should approach both insurance providers and foreign port authorities to ensure compliance, which includes ensuring the continual operation of AIS.
David Adesnik is director of research at the Foundation for Defense of Democracies. Follow him on Twitter @adesnik. Follow FDD on Twitter @FDD and follow FDD’s Center on Sanctions and Illicit Finance @FDD_CSIF. FDD is a Washington-based, nonpartisan research institute focusing on national security and foreign policy.