Iran Loads East of Hormuz: A New Export Node, a Live Toll Regime, and U.S. Enforcement at Sea

At a Glance

• Iran has activated the Kuh Mubarak offshore loading buoy on its Gulf of Oman coast as a recurring export node, lifting approximately 6.9 million barrels of Iranian Heavy crude over five months from a terminal that exported zero barrels through November 2025, with every barrel destined for China.
• An OFAC-sanctioned Aframax-class crude tanker was observed loading at Kuh Mubarak on May 18, the first Aframax lift at the terminal against a prior pattern of almost exclusively VLCC+ cargoes.
• The Persian Gulf Strait Authority (PGSA) went operationally live on May 18, with India, Iraq, and Pakistan securing bilateral access outside the formal fee structure while Chinese-linked and UAE-managed gray fleet operators absorb the toll regime.
• Three VLCCs transited the Strait outbound on May 20 — the first VLCC transits in the current reporting cycle — including a synchronized Chinese-controlled pair openly transmitting AIS and a South Korean-flagged VLCC in a 41-hour dark transit.
• The U.S. seized the Iran-linked VLCC SKYWAVE in the Indian Ocean overnight on May 19, the third U.S. seizure of an Iran-linked tanker in the current enforcement campaign.
• OFAC designated 19 Iran-trading vessels under a second Operation Economic Fury action, bringing the cumulative total to 28 designations in five weeks and extending into LPG carriers and corporate structures across China, Hong Kong, and the UAE.
• Fujairah port issued formal identity-theft enforcement notices against BALDMAN and EAN SPIR on May 18, the first publicly documented Gulf port action of its kind against Iran-linked tonnage.
• No shipment of Iranian oil has arrived in Asia for two weeks, with U.S. Central Command reporting 84 commercial vessels redirected and four disabled under the blockade on Iranian ports.

Operational Overview

The Iranian export environment shifted on two axes across May 19 and May 20, including an offshore crude loading node that has been activated on Iran’s Gulf of Oman coast outside the Strait of Hormuz, and U.S. enforcement has broadened into a parallel campaign across at-sea seizures, OFAC designations, and Gulf port action.

Kuh Mubarak, a single-point-mooring buoy roughly 110 nautical miles east of the Hormuz mouth, lifted zero barrels through the first eleven months of 2025 and approximately 6.9 million barrels of Iranian Heavy crude over the last five months, every barrel to China. May 18 saw the first Aframax-class loading, broadening an operator pool that had previously been almost exclusively VLCC+. May 19 imagery captured a second unidentified dark vessel seven nautical miles northwest of the buoy, raising the possibility of a secondary node.

The PGSA transit regime went operationally live on May 18. India, Iraq, and Pakistan are transiting under bilateral arrangements. Chinese-linked and UAE-managed gray and shadow fleet operators are absorbing tolls reported at up to $2 million per transit in yuan or cryptocurrency. No Western-flagged operator has publicly acknowledged payment. On May 20, two Chinese-controlled VLCCs transited Hormuz outbound in a tight 5–10 km formation, openly broadcasting AIS, marking the first observable signal of a tacit U.S.-China understanding on Chinese lifts of non-Iranian Gulf crude.

U.S. enforcement is running in parallel, with the SKYWAVE seizure in the Indian Ocean, OFAC’s second Operation Economic Fury package (19 vessels), and Fujairah’s identity-theft notices against BALDMAN and EAN SPIR. Hormuz is no longer characterized by closure but by tiered, contested, and structurally segmented access.

The combined picture is a Hormuz operating environment that is no longer characterized by closure but by tiered, contested, and structurally segmented access, with Iran’s export channel quietly migrating east of the Strait while the U.S. enforcement net widens across the Indian Ocean, Asian discharge ports, and Gulf anchorages.

Kuh Mubarak: An Offshore Export Node Outside Hormuz

Multi-collection SAR and EO imagery captured on May 18 at 07:38 UTC identified an OFAC-sanctioned Aframax-class crude tanker, a Guinea-flagged 244-meter vessel, moored at the Kuh Mubarak single-point-mooring buoy on the Iranian Gulf of Oman coast. The vessel sits approximately 110 nautical miles east of the Strait of Hormuz mouth, outside the standard Hormuz watch box.

The imagery shows the 244-meter hull made fast to the SPM buoy with small craft positioned forward and aft. The bow-on attitude, mooring hawser configuration, and assist-craft positioning are consistent with an active crude-loading operation rather than a routine anchor call. The vessel’s last AIS transmission was recorded approximately 13 hours prior to imaging on May 17 at 18:38 UTC, with the vessel assessed as having switched off its AIS transmitter on arrival at the station, consistent with a dark-on-arrival pattern. 

The voyage trail shows AIS broadcast off the Yemen coast on May 9, transit north into the southern Arabian Gulf on May 10, a 35.7-hour dark window between May 15 and May 16, continued northeast movement under AIS on May 16–18, and final AIS silence ahead of arrival at the buoy. The tanker is OFAC-sanctioned under the Iran program (EO 13902), with a Panama-domiciled owner that carries no public commercial fingerprint.

Vortexa flow data underscores the strategic significance of the terminal. Through the first eleven months of 2025, zero barrels moved out of Kuh Mubarak. In December 2025, the terminal lifted approximately 0.9 million barrels. Q1 2026 saw approximately 4.0 million barrels lifted, with an additional 2.0 million barrels in April 2026. Cumulative output over the last five months stands at approximately 6.9 million barrels of Iranian Heavy crude, every barrel destined for Chinese ports.

The May 18 lift is the first Aframax-class loading at the terminal, breaking a prior pattern of almost exclusively VLCC+ cargoes. Windward assesses the broadening of the operator pool as indicative of pressure on the available Iranian-linked tanker fleet, as Tehran is reaching deeper into its sanctioned-trade tonnage to keep volumes moving.

A second observation on May 19 may indicate that Kuh Mubarak is not the only node. Satellite imagery captured at 06:52 UTC identified an unidentified dark vessel and a prominent surface disturbance in the Gulf of Oman, approximately seven nautical miles northwest of the Kuh Mubarak buoy. The exact cause of the surface trail is unconfirmed and could represent standard single-point mooring operations, an operational malfunction or leak, or a kinetic incident. The vessel’s identity is not yet verified. Continued tracking is underway.

The broader assessment is that Iran has operationally established a crude export route outside the Strait of Hormuz that is structurally insulated from both the Strait blockade and the dysfunction at Kharg. The terminal provides Tehran with a sanitized offshore station to load and dispatch sanctioned tonnage without exposing it to the Strait’s disrupted traffic environment. Additional loadings at Kuh Mubarak are expected in the near term.

PGSA Goes Live: A Tiered Access Regime Visible in Vessel Behavior

Iran’s Persian Gulf Strait Authority transitioned from declared to operationally live on May 18, formalizing the toll mechanism. The system now runs alongside a parallel bilateral access tier, with India, Iraq, and Pakistan securing separate political arrangements outside the formal fee structure. All other operators face the toll regime, which is reported at up to two million U.S. dollars per transit in Chinese yuan or cryptocurrency, or the threat of seizure.

Iran assesses that the PGSA could generate two to three billion U.S. dollars annually at current suppressed transit levels, rising to seven to eight billion if pre-conflict transit volumes resume. Per-vessel toll revenue is estimated at five to thirty million U.S. dollars per day from compliant operators.

Compliance is splitting along structural lines. The operators paying PGSA tolls are predominantly Chinese-linked and UAE-managed gray and shadow fleet actors that cannot secure state-level cover. No Western-flagged operator has publicly acknowledged payment. The bifurcation is now visible in observable vessel behavior, most strikingly in the May 20 transit of two synchronized Chinese-controlled VLCCs through the Strait under open AIS broadcast.

The first vessel, a 299,170 DWT Hong Kong-flagged VLCC, loaded 918,800 barrels of Basrah Medium crude at the Iraqi ABOT terminal on February 25, followed by an additional 1.11 million barrels at Al Shaheen Terminal in Qatar on March 1–2, creating a blended Iraqi-Qatari cargo destined for Quanzhou, China. The vessel carries a high-risk compliance rating with the Iran-program association since March 19 and 24 dark periods totaling 467 hours between March and May, all flagged under the Iran sanctions program.

The second vessel, a 319,702 DWT China-flagged VLCC, loaded 1.87 million barrels of Basrah Medium at ABOT on February 27, with a destination of Ningbo, China. The vessel conducted a partial ship-to-ship transfer at Dubai on May 19, offloading 363,900 barrels to a separate tanker before continuing toward the Strait. It has 10 dark periods totaling 248 hours between March and May, all flagged under the Iran sanctions program, with May activity synchronized to its Hong Kong-flagged counterpart.

The two vessels are exiting the Gulf of Oman in a tight 5–10 kilometer formation, with Iraqi ABOT/SOMO crude as the common load anchor. The synchronized departure is the strongest single indicator of a coordinated operating protocol on this corridor rather than parallel coincidence. The open AIS transmission across the Strait, rather than masked movement, may indicate a tacit operational understanding between Washington and Beijing that Chinese-controlled lifts of Iraqi and Qatari crude are not primary enforcement targets under the current U.S. posture.

A separate South Korean-flagged VLCC is exiting the Strait in the same window but is not part of the synchronized Chinese pair. The vessel conducted three port calls at Assaluyeh, Iran, on March 7–8, totaling 9.6 hours. Its last AIS transmission was on May 18 at 23:51 UTC, with a 41-hour ongoing dark period during its Hormuz exit. The vessel is laden with 1.81 million barrels of Kuwait Export Crude loaded at Mina Al Ahmadi on March 3, destined for Ulsan and Onsan, South Korea. It carries a high-risk compliance rating with 13 dark periods between March and May, including a 56.9-hour window on May 11–13 and a 30.3-hour window on May 14–15. The vessel itself is not OFAC-sanctioned.

The three transits together indicate that selective large-tanker movement is resuming under tiered access conditions, but does not represent a return to normal commercial flow. What is visible is the operational tier of the PGSA regime hardening into observable vessel behavior, with two distinct compliance pathways now sitting side by side in the same transit window.

U.S. Enforcement Broadens: SKYWAVE, OFAC, and Fujairah

The United States seized the Iran-linked VLCC SKYWAVE in the Indian Ocean overnight on May 19, the third U.S. seizure of an Iran-linked tanker in the current enforcement campaign, following the April seizures of MAJESTIC X and TIFANI in the same area.

SKYWAVE, sailing under a fraudulent Botswana flag, was sanctioned by the United States in March for its role in transporting Iranian oil. Ship-tracking data showed the vessel sailing just west of Malaysia on May 19 after transiting the Malacca Strait, heading back to the Middle East after operating in an area known for ship-to-ship transfers. Open-source reporting indicating the vessel was laden with more than one million barrels of Iranian crude appears inconsistent with available draft data. SKYWAVE is a VLCC with a nominal capacity of approximately two million barrels, and its broadcast draft was consistent with a ballast condition rather than a laden one at the time of seizure. The operating profile, which includes discharging cargo off the Riau archipelago area in Malaysia’s EEZ before returning to the Middle East, is consistent with the standard modus operandi of Iranian seaborne logistics.

The seizure is separate from the U.S. blockade on Iranian ports being enforced in the Gulf of Oman and the Arabian Sea, and represents a distinct enforcement track targeting the shadow fleet at sea during its discharge cycle. Combined with the port blockade, U.S. enforcement is now operating along two parallel axes.

OFAC separately designated 19 Iran-trading vessels on May 19 under the second action of Operation Economic Fury. The package includes eight LPG tankers and four VLCCs, with the full set flagged outside Iran and tied to designated companies incorporated in China, Hong Kong, and the UAE. The action follows the inaugural Operation Economic Fury designation of nine vessels on April 15, bringing the cumulative total to 28 designated vessels in approximately five weeks.

OFAC stated that all 19 vessels were used to transport Iran-origin oil, petroleum products, and petrochemicals to foreign customers. At least 10 of the designated vessels are assessed to have been caught up in the U.S. blockade on Iranian ports after engaging in deceptive shipping practices to obfuscate their Iranian port calls. BRIGHT GOLD spoofed its position in Iraqi waters in early May to conceal loading in Iran. LPG carrier DAKUSH manipulated its AIS to fabricate a port call at Khor Al Zubair before sailing dark through the Strait of Hormuz in the same window. The expansion of designated tonnage to LPG carriers, alongside the broader crude-tanker pool, reinforces the picture of Iranian sanctions evasion extending across multiple cargo types and operator structures, with the U.S. enforcement response broadening in parallel.

Gulf port authorities are now part of the enforcement picture as well. The port of Fujairah issued formal notices on May 18 to two Iran-linked vessels operating under stolen identities, giving them until June 1 to provide valid documentation or face seizure and sale. Both vessels are currently at anchor at the port.

The first vessel, broadcasting as BALDMAN, was using IMO number 9389502. An Emirati investigation determined the IMO was fraudulently obtained from a vessel that has been stuck in a Ukrainian port since February 2022. The Comoros-flagged BALDMAN’s real identity is understood to be KEEL (IMO 9176929), a medium-range tanker sanctioned by the United States on January 24 for transporting Iranian naphtha. BALDMAN’s last AIS transmission was on May 11 while berthed at Fujairah, after the vessel arrived around the end of April. The second vessel, broadcasting as EAN SPIR (IMO 9298818), had taken the identity of a Mexican-flagged tanker. The vessel’s real identity is not yet publicly known. It arrived at Fujairah on May 2.

The Fujairah notice required the vessels to provide details of their real identity and related valid maritime documentation, re-mark and repaint all false identification on the ships’ hulls, deactivate fraudulent websites used to issue false classification and insurance certificates, and reprogram and update vessels’ systems and equipment. Vessel identity theft is one of the most advanced deceptive shipping practices used by Iran to evade sanctions, involving complex supporting fraudulent documentation, including fake QR codes, Q88 questionnaires, and other certificates from classification and insurance companies. The Fujairah action is the first publicly documented identity-theft enforcement against Iran-linked tonnage at a Gulf port and may serve as a template for similar actions across the region.

No Iranian Oil to Asia in Two Weeks

No shipment of Iranian oil has arrived in Asia for two weeks. The U.S. blockade imposed on April 13 has effectively cut off exports to China, the buyer of approximately 90% of Iran’s crude.

The last two shipments of Iranian oil tracked arriving in Asia were the U.S.-sanctioned Iranian-flagged tankers HUGE (IMO 9357183) and DERYA (IMO 9569700), which sailed through the Lombok Strait on May 3 and May 4, respectively. Both vessels were loaded before the embargo began, HUGE on April 1 and DERYA on March 19. The unusual Lombok Strait routing, through the narrow waterway between Bali and Lombok, was likely chosen to avoid detection on the more conventional and faster passage through the Strait of Malacca. The last vessel tracked inbound to Asia from Iran via the Strait of Malacca was on April 24, when the Iran-flagged HUMANITY (IMO 9180281) arrived in the region — also loaded before the embargo began.

The diminishing flow indicates that tankers have been unable to penetrate the blockade for at least four weeks, allowing for the 12–14 days of sailing time required from the Middle East. No Iranian-linked VLCC or Suezmax tanker has been monitored in the Straits of Malacca, Sunda, or Lombok with a cargo of oil during this period. U.S. Central Command reported on May 18 that 84 commercial vessels have been redirected and four disabled under the blockade on Iranian ports.

Just over a third of the approximately 78 tankers currently laden with Iranian oil are assessed to be in Asia, with approximately 11 in waters off China. These include five VLCCs and one Aframax tanker that broadcast via AIS at anchor off Rizhao, Dongjiakou, and Qingdao ports between April 26 and May 18. These three ports are among the five key terminals used by China’s so-called teapot refineries to import Iranian crude and have been identified by OFAC as a sanctions risk. The Lombok pivot that defined the early-May reroute pattern has now stalled, with Iran’s offshore Kuh Mubarak channel is positioning to take its place.

CRAVE Identified and Other Dark-Fleet Movements

Windward assesses with medium-to-high confidence that the dark LPG carrier observed at Kharg Island’s South LPG berth on May 16 at 07:42 UTC is CRAVE (IMO 9045807), a Mali-flagged vessel formerly named BATELEUR, MIRAMBO, and TEMSE. The vessel is OFAC-designated under EO 13846, having been listed on July 3, 2025, under its prior BATELEUR identity.

CRAVE called at Jaigad, India, on April 29 for a six-day port stay. A destination change was recorded on May 5 at 16:10 UTC, followed by the vessel’s last AIS broadcast at 20:28 UTC the same day in the Arabian Sea, with the AIS blackout beginning approximately four hours after the destination change. The vessel has remained continuously AIS-dark for 13 days and counting, the longest dark interval in its record and approximately five times the historical maximum. The identification is supported by EO imagery and the behavioral profile, including LPG-only cargo type, Kharg South LPG berth selection rather than the crude jetties, and Iran-attributed dark intervals on 10 of the last 11 dark periods between February and April 2026.

The CRAVE observation marks the first LPG carrier at the Kharg South LPG berth since the start of Operation Epic Fury and occurred within a six-day window of zero crude departures and approximately 20 tankers waiting offshore. On May 20, a 140-meter LPG tanker was observed transiting the Strait of Hormuz outbound in dark configuration, assessed with high confidence as the same CRAVE, a full Kharg-load-and-exit cycle now visible in the data.

Deceptive shipping practices are also broadening beyond the traditional dark-fleet tanker pool. SAR imagery collected over the Basrah Oil Terminal area on May 19 at 02:47 UTC identified nine vessels manipulating their reported positions in the port waiting area. Five are tankers, including crude oil and oil/chemicals tankers, with positions assessed as consistent with visits to Iran. The remaining four are cargo vessels, two bulk carriers and two general cargo vessels. Recent weeks have shown an increase in cargo vessels conducting location manipulation in the Basrah area, with ownership and management structures predominantly UAE-based. These cargo vessels have adopted the location-spoofing playbook previously associated with sanctions-evading tankers. The most probable motivation is the concealment of visits to the Bandar Imam Khomeini port to avoid detection by U.S. blockade enforcement.

Global Energy Flows Reorganize Around the Hormuz Disruption

The Hormuz environment is now driving second-order changes in sanctions enforcement and global oil routing beyond the Persian Gulf itself.

Russia is routing at least five EU/UK-sanctioned Russian-flagged Arctic LNG carriers around the Cape of Good Hope and through the Sunda Strait to China. This is a deliberate avoidance of the Mediterranean following the March 4 drone strike on the Russian-flagged LNG carrier ARCTIC METAGAZ east of Malta.

Separately, the U.S./EU/UK-sanctioned Aframax tanker VOYAGER (IMO 9843560) is delivering Russian oil to Japan under the U.S. waiver on Russian oil-on-water, extended for a third 30-day window on April 17. The delivery represents Japan’s second Russian crude purchase since the Russian invasion of Ukraine. The combination of the U.S. waiver and the UK’s recently softened Russian oil and gas sanctions regime indicates a widening reliance on case-by-case exemptions to maintain energy flows under prolonged Hormuz disruption.

Windward is separately monitoring a possible coordinated four-ship LNG export cluster from the U.S. Gulf Coast, with four LNG carriers having departed Lake Charles and Corpus Christi between May 10 and May 14 and now routing via the Atlantic and Cape of Good Hope toward Asia. One of the four is confirmed as Chinese-controlled and China-bound, with the remaining three assessed as plausible China-charter candidates. Combined cluster capacity is approximately 1.2 to 1.6 million cubic meters. Open-source reporting has linked the cluster to a possible U.S.-China accommodation on LNG flows, though Windward assesses the connection as inference-based and unconfirmed at this stage.

BARAKAH and the IRGC Posture

EO imagery collected over the southern Hormuz corridor on May 20 at 06:58 UTC identified BARAKAH stationary at its mid-strait position, consistent with the vessel’s posture since the May 4 IRGC drone strike. A swarm of 10 likely IRGC high-speed craft was observed approximately 3.5 nautical miles northwest of the vessel, heading northeast and likely departing from the Omani Peninsula direction.

The continued presence of IRGC small-craft activity in close proximity to BARAKAH, following the May 15 observation of boarding-preparation activity at the vessel’s stern, indicates sustained Iranian interest in the vessel through its eighth consecutive day of stationary posture. 

Six commercial transits through the Strait on May 19, four outbound and two inbound, all transmitting AIS, represent a decrease from the May 18 cycle’s 13 transits, with EO imagery on May 20 identifying three additional dark inbound vessels, including two 190-meter oil/chemical tankers and one 110-meter general cargo vessel.

A cargo vessel observed maintaining position in the Strait for the past several weeks was identified with containers piled only on its starboard side, which is a configuration consistent with protection or escort use for transiting vessels. A speedboat was observed in proximity to the vessel, possibly for crew exchange. The configuration is unusual and may indicate informal armed protection arrangements operating alongside the formal PGSA permit system.

Outlook

The Strait of Hormuz operating environment is no longer characterized by closure. It is characterized by tiered, contested, and structurally segmented access, with three distinct compliance pathways now operating in parallel and no neutral transit option.

The first pathway is bilateral carve-out: India, Iraq, and Pakistan transit under political arrangements outside the toll regime. The second is the PGSA toll tier: Chinese-linked and UAE-managed gray and shadow fleet operators paying up to two million U.S. dollars per transit in yuan or cryptocurrency, now visible in the synchronized Chinese VLCC pair openly transmitting AIS across the Strait. The third is enforcement exposure: vessels operating in dark configuration or with Iran-program associations remain subject to U.S. seizure at sea, OFAC designation, Gulf port enforcement action, and concurrent Iranian interdiction risk.

Layered on top is an Iranian export channel that increasingly operates outside the Strait altogether. Kuh Mubarak has moved from a dormant terminal to a working offshore export node lifting Iranian Heavy crude directly to China, with the May 18 Aframax loading and the May 19 unidentified vessel and surface trail nearby pointing to expansion rather than a single-buoy operation. With Iranian crude arrivals into Asia at zero for two weeks and the Lombok pivot now stalled, the offshore channel is positioning to absorb volumes that can no longer move through the conventional Malacca route.

The U.S. enforcement response is broadening in parallel with three at-sea seizures since the campaign began, 28 vessels designated under Operation Economic Fury, 84 vessels redirected under the port blockade, and the first publicly documented identity-theft enforcement at a Gulf port. The picture is one of an enforcement net that is widening geographically, while Iran’s export logistics are migrating to nodes the net does not yet fully cover.

The structural divide is hardening. Vessels operating in the Gulf of Oman approaches, particularly those with prior Iranian-linked behavioral profiles, falsified identities, or routing inconsistent with declared destinations, face elevated risk on multiple axes. Western-aligned tonnage remains effectively frozen out, absent continuous naval escort or bilateral state-level cover. The Hormuz environment that emerges from May 19–20 is one in which access is no longer determined by navigation but by flag, ownership, cargo origin, and the political tier the operator can secure.