Continuing to try to stem the flow of Iranian funding to the Houthis, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) took action March 15 against a Mumbai-headquartered, Marshall Islands-registered, shipping company Vishnu Inc., saying that its vessel, the Lady Sofia, has been involved in illicit shipments to the People’s Republic of China (PRC) in support of Iran’s Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF) and Houthi financial facilitator Sa’id al-Jamal, who is sanctioned under U.S. counterterrorism authorities.

“We remain committed to disrupting the IRGC-QF and the Houthis’ attempts to evade U.S. sanctions and fund additional terrorist attacks,” said Under Secretary of the Treasury for Terrorism and Financial Intelligence Brian E. Nelson. “The United States will continue to target the key funding streams that threaten civilians and peaceful international trade.”

AIS SPOOFING

According to the Equasis data base, the Lady Sofia is a 160,383 dwt, 2021-built, Panama-registered crude oil tanker. Treasury says that, on January 31, 2024, the Lady Sofia engaged in a ship-to-ship transfer with the recently sanctioned vessel Mehle, which deceptively obscured its transfer of commodities to the Lady Sofia through AIS spoofing.

“Disguised as a fictitious vessel called the “Amor,” and incorrectly broadcasting its location as the South China Sea, the Mehle offloaded its illicit cargo to the Lady Sofia near Singapore,“ says Treasury. “The Lady Sofia is currently traveling to the PRC, carrying the Iranian commodities it received from the Mehle on behalf of Sa’id al-Jamal.

The Mehle was identified on January 12, 2024, as property in which Cielo Maritime Ltd has an interest. Cielo Maritime Ltd was concurrently designated , for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, Sa’id al-Jamal.

Vishnu Inc. is being designated pfor having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, Sa’id al-Jamal. The Lady Sofia is being identified as property in which Vishnu Inc. has an interest.

SANCTIONS IMPLICATIONS

As a result of OFAC’s action, all property and interests in property of the designated person described above that are in the United States or in the possession or control of U.S. persons are blocked and must be reported to OFAC. In addition, any entities that are owned, directly or indirectly, individually or in the aggregate, 50 percent or more by one or more blocked persons are also blocked. Unless authorized by a general or specific license issued by OFAC, or exempt, OFAC’s regulations generally prohibit all transactions by U.S. persons or within (or transiting) the United States that involve any property or interests in property of designated or otherwise blocked persons.

In addition, financial institutions and other persons that engage in certain transactions or activities with the sanctioned entity and its blocked property may expose themselves to sanctions or be subject to an enforcement action. The prohibitions include the making of any contribution or provision of funds, goods, or services by, to, or for the benefit of any designated person, or the receipt of any contribution or provision of funds, goods, or services from any such person.