The Waiver, Then the Plug

Tanker tracking data compiled from AIS and satellite feeds shows Iran moved roughly 70 million barrels of crude and condensate to Asian buyers during the two-week U.S. sanctions waiver window that opened in late June. Cargo value ran to an estimated $5 to $6 billion at prevailing Dubai swap levels. On July 10 OFAC withdrew the license six weeks before its stated August 21 expiry. The revocation was accompanied by fresh SDN designations targeting shadow-fleet operators and a handful of Chinese teapot refiners.

What changed for counterparty screening

The updated designations bring the total sanctioned or listed tanker count over 1,100 vessels, a fleet share that MEI now estimates near 18% of global capacity. STS transfer patterns in the Gulf of Oman and off Malaysia have shifted again. Insurance clubs are asking for updated attestations on any cargo touching those corridors in the last 90 days. Documentation that was acceptable in May is being sent back for supplemental verification.

Our read

This is where a real KYC stack earns its keep. We run every counterparty and every vessel against live OFAC, OFSI, and EU consolidated lists on the day of nomination, not the day of contract signing. We check IMO numbers against dark-activity flags going back 24 months, not 12. Ship-to-ship history, flag hopping, and prior calls at sanctioned terminals all get reviewed before a Letter of Indemnity leaves our desk. The compliance perimeter is now the trade.