OFAC added 55 Iran shadow-fleet entries on 8 October. Treasury's release describes 34 of them

On Thursday 8 October 2026 OFAC added 55 entries to the SDN List and removed two. We counted them by hand on OFAC's page and found all 55 in the SDN file OFAC published the same day.

Treasury's headline says the action neutralises Iran's remaining shadow fleet. Its first paragraph narrows that to "effectively neutralizes the vast majority" of it. By Treasury's account, that fleet is ageing tankers that carry Iranian petroleum and petrochemicals to markets in South and East Asia. The release describes 17 ships and the companies that own them. OFAC's page lists more, and the gap is the first thing a reader checking a file against the news will run into.

The State Department's statement of the same day closes the gap. It says State is sanctioning "ten entities, six individuals, and five vessels" under Executive Order 13846, and that Treasury is sanctioning 17 entities and their ships under Executive Order 13902. Our count of the tags matches, entry for entry.

Treasury's release never gives a company count. It lists 13 firms under the petroleum or petrochemical sector and 5 under the petrochemical sector, 18 names, but Brich Shipping Company Limited is on both lists. That is 17 companies, one for each of the 17 ships.

The five State vessels are linked to three companies: Hessonite Ship Management, Horizon Ship Management and One Plus International. The other seven entities are Samudra Marine Services and SSPL Solutions in Mumbai, Noorzad Petrokimya, BGZ Dis Ticaret and Tuter Plastik in Turkey, Padideh Plastic Poshtiban in Tehran and ArabianPro Materials in Dubai. Each of the six individuals is linked to one of three: Samudra, SSPL Solutions or Noorzad Petrokimya.

General License EE is two paragraphs long. It authorises transactions "ordinarily incident and necessary" to winding down any dealing with Samudra Marine Services Private Limited, or with an entity Samudra owns 50 percent or more of, through 12:01 a.m. Eastern daylight time on 23 October 2026. A payment to a blocked person has to go into a blocked, interest-bearing account in the United States. Fifteen days is the whole grace period.

The licence authorises only transactions prohibited by E.O. 13846, and it says it does not authorise dealings with any other person blocked under that order. That leaves out the three individuals linked to Samudra. It also leaves out SSPL Solutions, which the licence does not name and which nothing OFAC published says Samudra owns. The 34 Treasury designations are outside it altogether, because they were blocked under a different order. Those 17 companies and their ships have no wind-down period at all.

OFAC also issued amended Russia General License 13S the same day. It has nothing to do with Iran. It lets US persons pay the taxes, fees and permit costs of their day-to-day operations in Russia that Directive 4 would otherwise prohibit, now through 12:01 a.m. Eastern standard time on 9 January 2027. General License 13R would have lapsed on 9 October.

Twenty of the 27 entities carry an IMO number. OFAC prints it as IMO and seven digits, the same form a ship's number takes, but under "Identification Number" for a company and "Vessel Registration Identification" for a ship. A loader that keys on the IMO prefix can put both in one column. A ship's number follows the hull for life. A company's number can come with leading zeros, 0008761 for Betta Shipping, and a loader that stores the field as an integer turns that into 8761.

In this batch the two do not overlap: every ship number begins with 9, every company number with 0 or 6. That is an accident of the list, not a rule. Check which of the two your file holds before matching on it, because a ship's number in a company column fails quietly.

The release and the list do not always spell a name alike. Treasury writes "Brich Shipping Co. Limited", while the SDN entry is BRICH SHIPPING COMPANY LIMITED, with the alias YONG SING SHIPPING COMPANY LIMITED. "Nostalgia Company Limited" is NOSTALGIA CO., LTD, "Gravion Maritime Company" is GRAVION MARITIME CO., and "JLS Dragon Co Ltd" is JLS DRAGON COMPANY LIMITED. Screen against the list's spelling, not the press release's.

Three more traps are in the data.

• GAS MARAKUA is the ship. MAKARUA SHIPPING LTD is its owner. The same letters, in two different orders.
• KANHA and PARITOSH each name a ship and the company that owns it (KANHA SHIPPING INC, PARITOSH SHIPPING INC.), so a hit on either word returns two entries. An analyst then has to say which one the cargo documents meant.
• Treasury's release calls ZIXUAN Vanuatu-flagged. Its SDN entry, published the same day, says Barbados. Flags change, and a flag is poor evidence that a ship is not the one listed.

Addresses are no better. All 10 Marshall Islands companies share one registered address in Majuro, so an address match returns all 10. In Mumbai the reverse happens. SSPL Solutions is at "1301 Juhu Prathna Chs Ltd, Building No 5", and Nisarg Samir Vora, linked to it, is at "1301, Building No.5, Juhu Prarthana". That looks like one flat, spelt two ways.

Eight are LPG tankers, five carry asphalt or bitumen, and the rest are crude, oil products and chemical tankers. The median ship was built in 2003. Flags and linked companies are as the SDN entries print them.

Two of the linked companies are registered in the United Kingdom: Saint Abundant International Co Ltd, in Coventry, and One Plus International Co Ltd, in London. OFAC listing a UK company does not put it on the UK Sanctions List, but a UK firm that deals with either now has a US problem as well.

OFAC deleted HAKUNA MATATA (IMO 9354167) and PINOCCHIO (IMO 9400112). Both are Liberian-flagged container ships, not tankers. Treasury says they were identified in June 2025 and have since been sold to non-sanctioned operators. Neither number appears in the SDN file published on 8 October.

Their old entries named MARVISE SMC DMCC as the linked company. That company stayed on the list, and so did 14 other vessels whose entries name it. A delisted ship no longer matches on its own number. The company it was linked to still does.

An alert raised on either ship before 8 October was a true match when it was raised. The file should show that, and it should show the date of the delisting, so nobody later reads a closed alert as a mistake.

1. Re-screen on IMO numbers. Run the 22 ship numbers against charter parties, bills of lading, port-agent files and insurance schedules. Do not rely on the name.
2. Re-screen the managers and owners by their list spelling, including the alias YONG SING SHIPPING COMPANY LIMITED.
3. Sort any hit by tag, not by headline. One [IRAN-EO13846] entry, Samudra, has a licence to rely on. No [IRAN-EO13902] entry does.
4. If Samudra Marine Services is in your book, give 23 October to a named person today. Money owed to Samudra goes into a blocked account, not to Samudra.
5. Look one level up from the vessel. Under OFAC's 50 percent rule a company that a blocked person owns half or more of is blocked without being named.
6. Keep the evidence. Record the entry, its tag and the list version you screened against.

A batch screening run here checks a supplier or vendor file against current OFAC, EU and UK data in one pass, with evidence for each row. A batch row is a name and an optional country, so the owners and managers above go in as the list prints them. The IMO numbers are for an analyst to compare by hand against the table above.

This is a reading of OFAC's 8 October page, Treasury's press release, the State Department's statement, General Licenses EE, 13S and 13R, and the SDN file OFAC published that day. We did not read the State Department fact sheet that its statement points to, and we did not check any of the 55 against EU or UK lists. The cargo and barrel figures in Treasury's release are Treasury's claims and are not part of the SDN entries, so we do not repeat them.

These are US measures. They do not bind an EU or UK firm directly, but they reach it through dollar payments and through the risk to its banks. Treasury warns that a foreign bank that knowingly handles a significant transaction for any of these parties risks conditions on its US correspondent account. A listing blocks the party named and anything it owns half or more of. It does not say that every ship that ever called at the same port is dirty.