In April 2020, a 114.2 m long ship called LAUREN, disappeared from the maritime surveillance space. A few days later he resurfaced on AIS international screens appearing out of nowhere in the same place where he had disappeared. It then entered UAE waters for a “ rendezvous ” with two other vessels on different occasions, one operated by a US sanctioned company.

What looks like the plot of a John le Carré novel is actually stranger than fiction. In about ten days at the end of April last year, the LAUREN performed the magic trick not once but twice.

During the flashes of dark sailor, satellite imagery reveals the red ship anchored in an Iranian LPG port it was never supposed to visit – it forged records by reporting it was heading for a port in Kuwait.

When approaching an area located less than three kilometers from the Exclusive Economic Zone (EEZ) of the United Arab Emirates, its operators consider it prudent to reactivate the AIS signal. There he meets two ships, one of them is the GAS SELLAN, another liquefied petroleum gas tanker reported in Vietnam.

AIS records map

The US authorities see the controversy in the operation and management of the ship by the Vietnam Gas and Chemical Transport Company, which does business in the transportation of petroleum, chemicals, LPG and bulk cargo.

Last december, Vietnam Gas and Chemicals Trans Corp (PCT.HN, previously Petro Cuu Long gas service), was added to the list of “specially designated nationals and stranded persons” (SDN) established by the United States Office of Foreign Assets Control (OFAC) of the United States Department of the Treasury. The list includes entities such as terrorists and drug traffickers for whom assets are stranded and with whom US entities are prohibited from doing business.

Operator review sites such as IFMAT Now indicate the entity with a red alert label. He is named or sanctioned for having contributed to “terror, weapons of mass destruction (WMD) and the violation of human rights”. He cites important transactions for the transport of petroleum products from Iran from November 5, 2018. The 40-year-old Vietnamese leader Vo Ngoc Phung, involved in the company’s activity, was also listed on OFAC’s SDN.

I contacted the company by email to request a statement regarding the events of last April. There was no response at the time of posting.

What happened?

Based on the forensic analysis of open data, the behavior displayed by three vessels (see map with AIS signal recordings) is “extremely strange,” an expert from a private imaging company said by satellite.

Data / credit: VesselFinder; Analysis: @BenHeubl

After two days in port with her AIS signal off, the LAUREN then met two ships on different occasions. Each time, before and after draw data suggests that the Lauren lost weight, indicating that some sort of cargo transshipment may have taken place. It all happened in the waters of the United Arab Emirates, 200-500m off the coast of Dubai.

The Strait of Hormuz is a busy place. It is the most important oil transit choke point in the world due to its oil flow. In 2019, the daily oil flow averaged 21 million barrels per day, or one-fifth of the global consumption of petro-liquids. Darkness is by no means a safe endeavor (nor for large reefer fishing vessels, we have found). However, due to growing fears of attacks such as oil tanker seizures or drone shootings, some vessel operators have often chosen to cut their AIS signal, Bloomberg data 2019 suggests.

However, in case of absence of AIS and at sea encounters involving LAUREN, GAS SELLAN and CROWN, now called Paula, suppose more devious intentions.

The behavior matches a general pattern that has been increasingly displayed by China recently for importing US-approved Iranian oil, helping to finance the Islamic Republic. According to a WSJ March ReportChina was expected to import 918,000 barrels of oil per day in March.

Now, the appetite may have widened to include LPG exports. IHS Markit recently cites strong demand for LPG from China, amid a wave of new petrochemicals added plants. The behavior last April, which potentially uses US-sanctioned Vietnamese operators as a means of commerce, is “suspect,” an expert from London-based maritime intelligence firm VesselsValue said. The analyst was not able to say for sure whether the gas was definitely transferred from one vessel to another, but believes that “something is obviously going on”.

“They [the three ships involved] wouldn’t go to the Middle East just to sit at anchor and do nothing. The changes in ships’ drafts – how deep the ship sits in the water, down to its cargo load – appear suspect, ”the representative explained.

AIS was developed as a navigation safety tool, an expert said. Deactivating it became a way of disguising the position of the ship. Additional information from AIS, such as’ following port of call‘and so on, also disappears in this way, says Jakob P. Larsen, at BIMCO, one of the largest international maritime associations representing shipowners. “Any ship involved in harmful activities can use it as a disguise. This is very common among sanction breakers or illegal fishing activities. When they feel safe again, they turn it on again ”.

guidance issued by the United States Departments of State and Treasury and the United States Coast Guard state that “although safety concerns can sometimes result in a legitimate deactivation of AIS transmission, vessels engaged in illicit activities may intentionally deactivate their AIS transmission. AIS transponders or manipulate the transmitted data in order to mask their movement ”.

Before the October 2020 point when the United Nations arms embargo on Iran expired, the UN Security Council sanctions did not impose restrictions on the export of Iranian oil.

Further investigation into the links between the management structures of Vietnam Gas and Chemicals Transportation Corp (CUU Long Petro Gas Service) and the three ships involved in the case last year shows his involvement – although none of the five own company ships did not participate.

The intelligence of VesselsValue shows that the company operates as GAS SELLANTechnical and ISM (International Safety Management) manager.

The manager of an oil tanker is the entity responsible for the technical aspect of things, such as maintenance, Feedback Explain. The operator is more important for the business operation and also for organizing the transshipment activity.

“The ship operator is responsible for the commercial operation of the ship, arranges the customers, what cargo to transport from A to B,” he adds.

In the case of GAS SELLAN, the operator (and owner) is reported as FGAS Petro Co. The Hanoi-based company has been added to the ‘Dirty List ‘last May, a roster of bad companies maintained by Burma Campaign UK, a human rights NGO. It includes entities that help the Myanmar military continue to commit human rights violations.

FGAS Petro is an energy and shipping company with the Bulk carrier Golden Amor, which uses the Ahlone International Port Terminal in Yangon, a terminal owned by the Burmese Army, responsible for a bloody crackdown this spring against unarmed protesters in the country, seeing hundreds of deaths.

Another vessel involved in the events of last April, the CROWN, now the Vietnamese flag PAULA, Is owned by Golden Lotus Oil Gas & Real, For who IMRRA Business Risk Rating aimed at managers and operators, gives a low trust score of 47%, making it a bold statement to the maritime business community that stakeholders are reviewing it.

Nhat Viet Transportation Corp, the beneficial owner of the vessel, IFMAT warns that its owner, PetroVietnam Transportation Corp (PVTrans), also carries a considerable risk for potential business partners. PVTrans was allegedly involved in “Iranian petroleum products knowingly transported on several occasions, using its fleet of tankers,” according to ITMAT, a human rights organization specialized in Iran.

the LAUREN, which disabled its AIS signal last year on its trip to Iran’s GPL port, belongs to Golden Lotus Petroleum Gas & Actual and operated / managed by Nhat Viet Transportation Corp.

For owners and managers involved in the events of the past year, this may have more significant effects than simply freezing holdings on US soil, Feedback said. “You can have cascading effects. If you are caught in the violation of sanctions, law enforcement is your responsibility. [as owner] by the US authorities can continue in cascade, as the case may be ”.

Analysts at HawkEye360, the Virginia-based satellite company that develops radio frequency (RF) satellite remote sensing and intelligence capabilities, say they have found another LPG tanker, the OPEC ATHENA, involved in apparent U.S. sanctions circumvention behavior in 2019.

The company used a model to find the transshipments. The case involving OPEC ATHENA, like the April 2020 case, also includes Vietnam Gas And Chemicals Transportation, this time as the vessel’s ISM manager. IHS Maritime cites FGAS Petro as owner and manager.

HawkEye360 cites evidence the ship visited Pars petrochemical port (port Asaluyeh), while turning off its AIS signal (in the same way the LAUREN did in 2020) and after anchoring in the United Arab Emirates, it sailed to Dongguan, China, where it arrived in December 2019.