Dear Secretary Lew and Secretary Kerry:
We commend the Treasury Department and the Department of State for the vital role they have played in continuing to tighten the sanctions against the Islamic Republic of Iran. The enforcement of these sanctions is paramount in the efforts to dissuade Iran from pursuing its nuclear program. With this in mind, we are concerned that Iran has been able to continue its illicit shipping endeavors through its complex web of vessels reflagging. It troubles us that Iran has been aided by countries whose shipping registries are frequently complicit in this shell game. We urge the Treasury Department and the Department of State to seriously consider sanctioning registries that knowingly participate in efforts to reflag oil tankers and cargo vessels that are operated by the National Iranian Tanker Company (NITC) and the Islamic Republic of Iran Shipping Line (IRISL).
We appreciate the terrific work of the Office of Foreign Asset Control (OFAC), in consultation with the Department of State, to designate Iranian merchant vessels, particularly in light of the extensive efforts made by Iran to hide the ownerships and nationality of control. We would like to bring to your attention three particular vessels that, to the best of our knowledge, have so far not been added to the OFAC list. We urge you to review these vessels to determine whether they should be added to the Specially Designated Nationals (SDN) list.
These vessels include The Tour 2 (IMO 9364112, a 158,719 DWT crude oil tanker reportedly owned by the Irano-Hind Shipping Company whose flag is unclear), The Justice (IMO 9357729, a 319,999DWT crude oil tanker reportedly owned by NITC and recently flagged to Tanzania), and The Elegance (IMO 9283758, a 35,118 DWT product tanker reportedly owned by NITC and recently flagged to Tanzania).
We are troubled by the seemingly illicit actions of these vessels. For example, The Tour 2 has made two round trips between Iran and Syria via Egypt over the past year, was recently en route from Syria to Egypt via Cyprus, and now appears to be preparing to transit the Suez Canal, possibly returning yet again to Iran. This vessel was originally flagged to Iran and has since gone through Maltese, Bolivian, Sierra Leonean and Togolese flag registries.
Further, The Justice was formerly known as the Dadgar, and was originally flagged to Iran, but subsequently reflagged to Cyprus and then Tanzania. The Justice was recently reported as in Iran after a voyage to China.
Likewise, The Elegance, which was originally known as the Iran Faraz and was originally flagged to Iran, but subsequently reflagged to Tuvalu and then Tanzania. The Elegance has just returned to Iran from a voyage to China.
We understand that some shipping vessels, due in part to the extensive efforts Iran undertakes to hide their true country of origin, fall through the cracks. We trust that we will be able to work with you to ensure that this is a rare occurrence and that our sanctions enforcement is timely and effective.
We urge the Treasury Department and the Department of State to take swift action in this matter and ask you to inform us once a determination about their designation has been made. Thank you again for your efforts to date.
Peter J. Roksam Theodore E. Deutch