I'm sure everyone remembers that on Sept. 10 of last year, OFAC added the 123 vessels of Islamic Republic of Iran Shipping Lines to the SDN list under the Nuclear Proliferation/Weapons of Mass Destruction program.

What you might not know is that since that listing IRISL has renamed 46 of those vessels. Fortunately, renaming a ship doesn't change the unique IMO registration number of the vessel, and the IMO number was included in the Sept. 10th listing of the vessels.

So, as long as your OFAC scans include the IMO number for vessels, you should be OK. Just to be completely safe, however, listed below are the OFAC listed names, IMO numbers and the new names of the 46 renamed vessels.

• BRILLIANCE (a.k.a. IRISL - IRAN BRILLIANCE);IMO 9051636 (vessel) [NPWMD] renamed to Mulberry on 11/16/2008
• DAPPER (a.k.a. IRISL - IRAN DAPPER);IMO 8309646 (vessel) [NPWMD] renamed to Angel on 01/23/2009
• DIGNIFIED (a.k.a. IRAN DIGNIFIED); IMO 8309610 (vessel) [NPWMD] renamed to Aquarian on 01/02/2009
• ELEVENTH OCEAN;IMO 9209324 (vessel) [NPWMD] renamed to Daffodil on 12/12/2008
• FIFTH OCEAN;IMO 9349667 (vessel) [NPWMD] renamed to Decker on 12/24/2008
• IRAN AFZAL;IMO 8105284 (vessel) [NPWMD] renamed to Parmida on 12/31/2008
• IRAN AMANAT;IMO 8112990 (vessel) [NPWMD] renamed to Tabak on 12/31/2008
• IRAN ARDEBIL;IMO 9284154 (vessel) [NPWMD] renamed to Sepanta on 01/20/2009
• IRAN AZADI;IMO 7632838 (vessel) [NPWMD] renamed to Anoosh on 01/20/2009
• IRAN BAM; IMO 9323833 (vessel) [NPWMD] renamed to Horsham on 01/17/2009
• IRAN BIRJAND;IMO 9305219 (vessel) [NPWMD] renamed to Tongham on 01/20/2009
• IRAN BOJNOORD;IMO 9305207 (vessel) [NPWMD] renamed to Uppercourt on 01/23/2009
• IRAN BRAVE;IMO 9051650 (vessel) [NPWMD] renamed to Margrave on 01/05/2009
• IRAN BROOJERDI;IMO 7502722 (vessel) [NPWMD] renamed to Dinnax on 11/26/2008
• IRAN BUSHEHR;IMO 9270658 (vessel) [NPWMD] renamed to Silver Zone on 12/31/2008
• IRAN DEYANAT;IMO 8107579 (vessel) [NPWMD] renamed to Markarid on 01/09/2009
• IRAN DOLPHIN;IMO 8320195 (vessel) [NPWMD] renamed to Alameda on 01/01/2009
• IRAN ENTEKHAB;IMO 7632814 (vessel) [NPWMD] renamed to Assa on 01/11/2009
• IRAN GHAZI;IMO 8309672 (vessel) [NPWMD] renamed to Ajax on 12/31/2008
• IRAN ILAM;IMO 9283033 (vessel) [NPWMD] renamed to Sepitam on 12/31/2008
• IRAN KOLAHDOOZ;IMO 7428809 (vessel) [NPWMD] renamed to Despina on 01/13/2009
• IRAN MADANI;IMO 8309622 (vessel) [NPWMD] renamed to Adventist on 12/14/2008
• IRAN NAVAB (a.k.a. IRISL -IRAN DESTINY);IMO 8320145 (vessel) [NPWMD] renamed to Apollo on 01/30/2009
• IRAN PIROOZI;IMO 9283007 (vessel) [NPWMD] renamed to Sakas on 01/14/2009
• IRAN SEPAH;IMO 7375363 (vessel) [NPWMD] renamed to Hootan on 01/20/2009
• IRAN SHARIAT;IMO 8107581 (vessel) [NPWMD] renamed to Barsam on 01/12/2009
• IRAN TABAS;IMO 9305192 (vessel) [NPWMD] renamed to Shere on 11/24/2008
• IRAN TAKHTI;IMO 7602194 (vessel) [NPWMD] renamed to Zaven on 12/29/2008
• IRAN YASOOJ;IMO 9284142 (vessel) [NPWMD] renamed to Simber on 12/25/2008
• IRAN ZANJAN;IMO 9283019 (vessel) [NPWMD] renamed to Visea on 01/27/2009
• LUCKY LILY (a.k.a. IRAN LUCKY LILY);IMO 9165827 (vessel) [NPWMD] renamed to Golden Rod on 12/11/2008
• LUCKY MAN (a.k.a. IRAN LUCKY MAN);IMO 9165839 (vessel) [NPWMD] renamed to Garland on 12/02/2008
• MIR DAMAD;IMO 9148491 (vessel) [NPWMD] renamed to Ocean Bride on 10/27/2008
• NEW STATE (a.k.a. IRAN NEW STATE);IMO 9209336 (vessel) [NPWMD] renamed to Dandelion on 11/12/2008
• NINTH OCEAN;IMO 9165798 (vessel) [NPWMD] renamed to Galax on 01/15/2009
• OCEAN CANDLE (a.k.a. IRAN OCEAN CANDLE);IMO 9167253 (vessel) [NPWMD] renamed to Lantana on 01/05/2009
• PRETTY SEA (a.k.a. IRAN PRETTY SEA (KHUZESTAN));IMO 9167277 (vessel) [NPWMD] renamed to Lavender on 12/11/2008
• SEA BLOOM (a.k.a. IRAN SEA BLOOM);IMO 9167291 (vessel) [NPWMD] renamed to Lodestar on 12/03/2008
• SEA FLOWER;IMO 9167289 (vessel) [NPWMD] renamed to Limnetic on 11/15/2008
• SEA STATE (a.k.a. IRAN SEA STATE);IMO 9167265 (vessel) [NPWMD] renamed to Lilied on 11/20/2008
• SEVENTH OCEAN;IMO 9165786 (vessel) [NPWMD] renamed to Gabion on 11/27/2008
• SIXTH OCEAN;IMO 9349679 (vessel) [NPWMD] renamed to Decretive on 12/15/2008
• TENTH OCEAN;IMO 9165815 (vessel) [NPWMD] renamed to Gladiolus on 12/10/2008
• TWELFTH OCEAN;IMO 9209348 (vessel) [NPWMD] renamed to Dandle on 12/10/2008
• VAAFI (a.k.a. IRAN VAAFI);IMO 9387786 (vessel) [NPWMD] renamed to Chimes on 01/28/2009

How did you get this information?

Lloyd's Register

The Islamic Republic of Iran Shipping Line has renamed additional ships that OFAC listed under the NPWMD program. The renamed ships are:

• vessel listed as BRIGHTNESS ; IMO 9051648. under NPWMD is now named MARIGOLD
• vessel listed as DAIS ; IMO 8309696. under NPWMD is now named ADMIRAL
• vessel listed as DANDY ; IMO 8320157. under NPWMD is now named ANIL
• vessel listed as DECOROUS ; IMO 8309658. under NPWMD is now named AGILE
• vessel listed as DELEGATE ; IMO 8320121. under NPWMD is now named AEROLITE
• vessel listed as DELIGHT ; IMO 8320133. under NPWMD is now named ADRIAN
• vessel listed as DEVELOPER ; IMO 8309660. under NPWMD is now named AFFLATUS
• vessel listed as DEVOTEE ; IMO 8309608. under NPWMD is now named ALIAS
• vessel listed as DEVOTIONAL ; IMO 8309684. under NPWMD is now named ACROBAT
• vessel listed as DIAMOND ; IMO 8309593. under NPWMD is now named ATTRIBUTE
• vessel listed as DIPLOMAT ; IMO 8309701. under NPWMD is now named AMPLIFY
• vessel listed as DREAMLAND ; IMO 8320183. under NPWMD is now named ATLANTIC
• vessel listed as DRIFTER ; IMO 8320169. under NPWMD is now named ACCURATE
• vessel listed as DYNAMIZE ; IMO 8309634. under NPWMD is now named AGEAN
• vessel listed as IRAN ADL ; IMO 8108559. under NPWMD is now named PANTEA
• vessel listed as IRAN BAGHAEI ; IMO 7502734. under NPWMD is now named KIJEA
• vessel listed as IRAN BAGHERI ; IMO 7428811. under NPWMD is now named DANOOSH
• vessel listed as IRAN ESTEGHLAL ; IMO 7620550. under NPWMD is now named GOMIDAS
• vessel listed as IRAN FARS ; IMO 9283021. under NPWMD is now named SEWAK
• vessel listed as IRAN GILAN ; IMO 9193202. under NPWMD is now named BLUEBELL
• vessel listed as IRAN HAMZEH ; IMO 8320171. under NPWMD is now named ATRIUM
• vessel listed as IRAN HORMUZ 26 ; IMO 8422084. under NPWMD is now named SADAF POSHTIBAN
• vessel listed as IRAN JOMHURI ; IMO 7632826. under NPWMD is now named AMITEES
• vessel listed as IRAN KERMAN ; IMO 9209350. under NPWMD is now named SILVER CRAFT
• vessel listed as IRAN KERMANSHAH ; IMO 9213399. under NPWMD is now named ACENA
• vessel listed as IRAN MATIN ; IMO 9051624. under NPWMD is now named ABBA
• vessel listed as IRAN SHARIAT ; IMO 8107581. under NPWMD is now named BARSAM 
• vessel listed as IRAN TEYFOURI ; IMO 7602211. under NPWMD is now named ZOORIK 
• vessel listed as IRAN TUCHAL ; IMO 9346536. under NPWMD is now named TUCHAL
• vessel listed as IRAN YAZD ; IMO 9213387. under NPWMD is now named LANCELIN
• vessel listed as MIR DAMAD ; IMO 9148491. under NPWMD is now named BAI HANDELAS 
• vessel listed as MIR EMAD ; IMO 9148518. under NPWMD is now named BAI LAL
• vessel listed as PERSIAN GULF ; IMO 9305221. under NPWMD is now named VOBSTER
• vessel listed as SHAAFI ; IMO 9386500. under NPWMD is now named CHASTITY

In addition, ownership of these vessels has been transferred to a number of shell entities (still located in Iran, though it wouldn't be obvious from their names), and operating companies. Some have been re-flagged, so instead of sailing under the Iranian flag, some are sailing under the German flag, for example.

If your sanction program involves scanning for vessels, you need to check IMO numbers. It is the only aspect of a ship's identity that cannot be changed.

I have no experience with vessels, so I apologize if my question appears dumb.

By virtue of these vessels being on the list, are they denied access to U.S. ports?

I realize that cargo could be placed on board at non-U.S. ports, but I'm curious if they are allowed to dock in the U.S.

No, they would not be allowed in a U.S. port.
More interesting, absent an OFAC license, if a U.S. bank has financed goods (through a commercial letter of credit, for example), the goods cannot be loaded onto the listed ships no matter what port they are in.

Minor clarification. Is it that the goods cannot be loaded on the vessel, or that the U.S. bank cannot finance the transaction that has anything to do with the goods?

In other words, even if the goods are never loaded on the vessel, the U.S. bank would still be in violation if it was party to any part of the financial transaction. Right?

Edit: Wait a minute, since the vessel is on the list, then I suppose the transaction to purchase or ship the goods would be OK as long as none of parties involved with selling, purchasing, or transporting the goods are not on a list.

You're right, I was a little unclear. U.S. banks cannot finance any goods that are destined to be shipped on the listed vessels.

So your edit comment is exactly right. The issue with automated scanning systems is that OFAC hasn't updated their listing of the vessels to reflect their new names. It's up to groups that do scanning to either track the name changes, or to hold transactions until you get the vessel's IMO number.

When the vessels were initially listed in Sept. 2008, there was a tremendous problem with those 123 vessels. To the extent that the goods were financed by US banks, companies could not be paid for delivery, so the the sellers wouldn't release the goods, banks couldn't handle the bills of lading and delivery documents either. The Iran program is a total block, so no one had the luxury of simply rejecting the transactions.

You never know who is reading our posts here.

The WSJ mentions this thread in an article here .

A list updated as of 3/17/2010 courtesy of IranWatch , which includes some new holding company names and new ship names.

Well, OFAC caught up, sort of. In the recent NPWMD update, they added the new ship names, 24 new vessels, and 2 of the 60+ shell companies.

Maybe in another round they will add the remaining shell companies, and possibly even Nigel Malpass, who helped set them up.

I'm not holding my breath, though.

If you want a pretty current listing of the shell companies, and you don't think you can justify adding them to your interdiction software by saying 'some guy on banking blog said so', here's an open-source version : NY Times article.

From the article, you can access a complete listing and description of the shell companies.

Hello,

How do you stop those wires that deal with vessels? Do you stop all wires that contain a clue word " vessel, ocean, etc"?

or do you only stop wires if they contain/include the name of a vessel or IMO that is a possible OFAC hit?