Yesterday’s OFAC Sanctions – National Security & Sanctions or Compliance Risk Converge (Again)

Yesterday’s OFAC sanctions announcement that targeted individuals and entities linked to Russia and Iran’s Islamic Revolutionary Guard Corps (IRGC) underscores two growing trends: 

• The convergence of national security and sanctions compliance risk management
• The importance of knowing what’s happening BEFORE official announcements 

The transfer of advanced weaponry, including ballistic missiles and unmanned aerial vehicles (UAVs), from Iran to Russia highlights the increasing complexity of global threats. Traditional risk assessments must consider the heightened intersection between geopolitical instability and the commercial sector, requiring a more proactive and integrated approach to safeguarding operations.

Iranian Missiles for Russian Grain?  

The Office of Foreign Assets Control (OFAC) of the U.S. Department of the Treasury yesterday (September 10) sanctioned several individuals and their companies related to Russia and Iran’s IRGC. 

OFAC sanctioned 9 vessels due to their illicit behavior and association with the Russian Ministry of Defense. The vessels:  

• Kompozitor Rakhmanin (IMO: 8606616)
• Boriskustodiv (IMO: 9103817)
• Omskiy 103 (IMO: 8889385)
• Omskiy-119 (IMO: 8926913)
• Port Olya-3 (IMO: 9481910)
• Port Olya-4 (IMO: 9481934)
• Vafa (IMO: 8422670)
• Vafa-1 (IMO: 8422682)
• Zakamsk (IMO: 8951413)

Media outlets have been speculating, based on a comment by an Iranian lawmaker, that Iran may be sending weapons systems to Russia in exchange for Russian wheat and other grains. Iran has officially denied these allegations. It is possible that these sanctioned vessels might be enabling this illicit trade.

See the next section for more evidence of grain training (port analysis). On a related note, we have written extensively on Russian grain smuggling from Ukraine following Russia’s invasion. 

Windward Users Already Knew by 2019…

Windward customers don’t wait for official OFAC (or other regulatory bodies’) announcements. They are automatically alerted about vessels that potentially endanger their trading and shipping operations, or that pose a threat to national/international security (or both). 

Historically,  86% of sanctioned vessels have been flagged as high risk by Windward in the year prior (at least) to their sanctioning. 
All of the nine vessels were flagged by Windward as high risk between 2013-2019, due to dark activities, port calls in sanctioned regimes, and loitering activities conducted in Iran and Russia, especially in the Caspian Sea.

For organizations that aren’t yet Windward customers, here’s what you need to know: 

Windward’s AI-generated data shows that all vessels are Russian-flagged cargo vessels. Most of them are general cargo vessels and bulk carriers, with one roll-on/roll-off vessel. The vessels range in size from 82-126 meters in length. The vast majority were built before the year 2000, with most of them constructed in the 1980s.

Based on the vessel’s historical data contained in the Windward Maritime AI™ platform, all of the vessels have been operating in the Caspian Sea since 2017, with rare visits to the Black Sea after sailing through the Volga River. 

The Zakamsk, Omskiy-119, Port Olya-4, Port Olya-3, and Boriskustodiv previously operated in the Black Sea, before starting operations in the Caspian Sea, while the rest of the vessels operated exclusively within the Caspian Sea.

Based on the vessels’ transmissions, their home ports are located in Astarakhan and Olya, Russia. Their preferred ports of destination (PoD) in Iran are mostly Amirabad, Bandar-e Anzali and Nowshahr, all suggested by public sources to have an IRGC presence. Based on satellite imagery and Windward port call data, it appears that these ports usually handle general cargo shipments and grain-loading, based on the silos located in the port.

The Convergence 

As national security and risk management continue to intertwine, businesses and governments alike must adapt. The Russian-Iran-China alliance and the intensification of the great power competition, plus Russia and China-flagged vessels increasing their presence in the Arctic for liquid natural gas (LNG) transactions, has helped merge the spheres.   

This convergence signals a need for enhanced vigilance and strategic foresight. Whether it’s monitoring sanctions, tracking vessels of interest, or assessing regional volatility, stakeholders would be wise to embrace comprehensive solutions that can navigate the blurred lines between global security threats and commercial risks. The latest OFAC sanctions are a reminder that in today’s world, ripple effects aren’t contained by previous dividers. 

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