The U.S. Department of the Treasury has designated a number of front companies and individuals for allegedly acting on behalf of the Islamic Republic of Iran Shipping Lines (“IRISL”). The actions were not taken pursuant to the Non-Proliferation Sanctions Regulations implemented by Executive Order (E.O.) 13382.

IRISL was designated in September 2008, for the provision of logistical services to the arm of the Iranian military overseeing Iran’s ballistic missile program. According to the U.S. Department of the Treasury, IRISL has been involved in the creation of a series of front companies and engages in deceptive behavior to to evade the impact of sanctions against its activities. In addition to these newest designations, Treasury has designated nearly 170 IRISL front companies and ships.

The individuals who have been designated include Mohamad Talai, Mansour Eslami, Ahmad Sarkandi, Ghasem Nabipour, and Naser Bateni. The companies designated include: Darya Capital Administration GMBH, Eighth Ocean Administration GMBH, Eighth Ocean GMBH CO. KG, Eleventh Ocean Administration GMBH, Eleventh Ocean GMBH & CO. KG, Fifteenth Ocean GMBH & CO. KG, Fifth Ocean Administration GMBH, Fifth Ocean GMBH & CO. KG, First Ocean Administration GMBH, Fourteenth Ocean GMBH & CO. KG, Fourth Ocean Administration GMBH, Fourth Ocean GMBH & CO. KG, Ninth Ocean Administration GMBH, Ninth Ocean GMBH & CO. KG, Second Ocean Administration GMBH, Second Ocean GMBH & CO. KG, Seventh Ocean Administration GMBH, Seventh Ocean GMBH & CO. KG, Sixth Ocean Administration GMBH, Sixth Ocean GMBH & CO. KG, Tenth Ocean GMBH & CO. KG, Third Ocean Administration GMBH, Third Ocean GMBH & CO. KG, Thirteenth Ocean GMBH & CO. KG, Twelfth Ocean Administration GMBH, Twelfth Ocean GMBH & CO. KG, HTTS Hanseatic Trade Trust and Shipping, GMBH, Kerman Shipping CO LTD, Lancelin Shipping Company Limited, Nari Shipping and Chartering GMBH & CO. KG, Ocean Capital Administration GMBH, Shere Shipping Company Limited, Tongham Shipping CO LTD, Uppercourt Shipping Company Limited, Vobster Shipping Company LTD, and Woking Shipping Investments Limited.

According to Under Secretary for Terrorism and Financial Intelligence Stuart Levey, “This pattern of obfuscation is leading the private sector around the world to refuse business with Iran rather than risk becoming involved in its nuclear and missile programs.” This certainly seems to be the case and is a phenomenon that I commented on earlier this week.

The author of this blog is Erich Ferrari, an attorney specializing in OFAC litigation. If you have any questions please contact him at 202-280-6370 at 202-351-6161 or ferrari@ferrari-legal.com.