Iran’s Transport Network in Hong Kong for a Decade, Hong Kong Government Ignores Sanctions Order, Scholar: U.S. Watching Closely

Radio Free Asia found that the National Iranian Shipping Company (NIS) holds at least 10 ocean-going cargo ships and five oil tankers through Hong Kong, and that the network has shifted to a post-90s Shanghai resident in recent years.

Earlier the U.S. sanctioned four Hong Kong companies in connection with helping Iran break the embargo. Radio Free Asia’s Transnational Division cooperated in an investigation that uncovered an Iranian shipping network in Hong Kong that was transferred to a mysterious Shanghai post-1990s owner in 2018. The network is controlled behind the scenes by the Iranian National Shipping Lines (IRISL), which is under U.S. sanctions and holds at least 37 companies and 15 ocean-going vessels through Hong Kong.

Iranian Network in Hong Kong. Series 1]

Four of the Hong Kong companies under investigation in this investigation of Iran’s clandestine transportation network in Hong Kong were sanctioned by the United States last month. At the time, we discovered that the same Shanghai man, “Shen Yong”, was the director of four of the companies (see separate article).

Nearly 200 copies of the shipping hub that connected to Air Iran’s port construction have been traced.

This reporter further searched through nearly 200 Hong Kong and foreign documents and discovered that there are currently 37 companies registered in Hong Kong, most of which are related to the Iranian National Shipping Line (IRISL), an extensive transportation network that owns at least 10 ocean-going cargo vessels and 5 oil tankers. IRISL has been accused of transporting ballistic missiles and proliferation-related nuclear materials for Iran, and is a frequent target of sanctions, which are still under U.S. sanctions.

IRISL’s network of companies was first established in Hong Kong in 2008 and is held through a number of shell companies. 2010 Iran was sanctioned by the United Nations, and it was not until 2016, when Iran and other countries reached the “Iran Deal”, which imposed a moratorium on nuclear weapons development, that the United Nations lifted economic sanctions on Iran, and IRISL benefited from the lifting of those sanctions. Sanctions. After 2016, IRISL establishes at least 10 more companies in Hong Kong, expanding its Hong Kong footprint and becoming high-profile, acting directly as sole shareholder of 10 subsidiaries.

IRISL became a shareholder in 2018, the same year the U.S. withdrew from the Iran nuclear deal.

However, since 2018, a number of IRISL’s Hong Kong affiliates have changed their single shareholder to a Cyprus registered company, “Montenavo Shipping Company limited” and “Santarosa Shipping Company limited” (hereinafter referred to as “Montenavo” and “Santarosa”).

We obtained the Cyprus registrations of these two companies and discovered that they are owned by a Shanghai post-90’s “ChengCheng Dai”. Fateh Tamiji is the former CEO of ROD Ship Management, a subsidiary of IRISL that has been sanctioned in Europe and the United States for arms shipments.

It is worth noting that the Trump administration announced in 2018 that it was withdrawing from the previously signed Iran nuclear deal, then gradually reintroduced sanctions, and in 2019 further terminated the exemption of secondary sanctions for countries that buy Iranian oil. In other words, IRISL’s business is once again becoming sensitive.

According to Ross Feingold, a political risk management consultant in the US, China, Hong Kong and Iran have long traded with each other. A number of Iranian shipping companies will set up their companies and headquarters in Hong Kong, and “if you want to get around the U.S. sanctions or hide, of course you want to be in a big port and a place with frequent shipping,” he said.

Under the current U.S.-China relationship, the U.S. will often take a Whole-of-Government Approach and devote more resources to investigating China’s actions, whether official or corporate,” says Fanger.

Entity holders? Evading embargo puppets?

No specific background information is known about “ChengCheng Dai” except that she was born in 1992 and her address is “Shanghai Heching Chunlei Village”. Why is IRISL’s Hong Kong network owned by a post-90’s Shanghai shareholder? What exactly is “ChengCheng Dai” the real power holder? Or is IRISL used as a puppet to circumvent the embargo? The reporter emailed IRISL for more information, but there was no reply before the deadline. However, based on the fact that the U.S. sanctioned the company in October after the shareholding change, it is inferred that the shareholding change does not affect the company’s close relationship with Iran.

U.S. Sanctions May Affect Hong Kong Amid Close China-Iran Ties

China and Iran are reportedly working toward a 25-year comprehensive cooperation agreement that will see China continue to buy Iranian oil and become a major investor and partner in Iran’s security and political spheres. As Iran is under severe U.S. sanctions, relations between Iran and China are developing, and may continue to deteriorate, and Hong Kong may also be affected.

Robert Clifton Burns, a former associate professor of law at Georgetown University Law Center who specializes in economic sanctions and is now in private practice, explains that U.S. secondary sanctions against Iran can work against non-U.S. entities as well.

Robert Clifton Burns: I think that secondary sanctions are a concern for many foreign banks because they don’t require complicated links to be sanctioned. If a foreign bank is involved in providing financial services to Iran, such as automatic weapons or crude oil, up to a certain amount, it can be sanctioned, even if it has nothing to do with the United States.

China is Iran’s largest exporter of oil, and Iran is very hungry for Chinese electronics and technology products. “To a certain extent, China can ignore the unilateral sanctions and continue to trade with China.

Radio Free Asia found out that IRISL, which was named in a UN sanction, is still operating in Hong Kong.

Earlier U.S. sanctioned four Hong Kong companies for helping Iran break the embargo. In a joint investigation by the multinational division of Radio Free Asia, it was discovered that the U.S.-sanctioned Iranian National Shipping Company (IRISL) is behind the control of Hong Kong’s transportation network, with at least 37 companies and 15 ocean-going vessels in Hong Kong. The Hong Kong Commerce and Economic Development Bureau replied that the Hong Kong government has been following the instructions of China’s Ministry of Foreign Affairs to strictly enforce the sanctions imposed by the United Nations Security Council (UNSC).

The Iranian network in Hong Kong. Series II]

Documents show that IRISL’s network of companies was first established in Hong Kong in 2008 and is held through shell companies; Iran was sanctioned by the United Nations in 2010 and economic sanctions were only lifted in 2016 after Iran reached an “Iran deal” with countries to suspend development of nuclear weapons.

UN: All Countries Should Freeze IRISL Assets

The 2010 “1929 Resolution” of the UN Resolution makes it clear that all countries should freeze IRISL or IRISL’s agents, or entities, funds, other financial assets and economic resources owned or controlled by them. However, at least 11 of IRISL’s key Hong Kong companies, as far as this reporter can see, were already operating in Hong Kong during the period of UN sanctions.

For example, one of IRISL’s subsidiaries, Ideal Success Investment Limited, was founded in 2008 with Ahmad Sarkandi and Ghasem Nabipour as shareholders and directors, both of whom were IRISL executives at the time of the U.S. sanctions.

The company’s information is registered with the Companies Registry, and the South China Morning Post (SCMP) has already mentioned the company in a May 1, 2011 report investigating IRISL’s network in Hong Kong. However, the company continues to operate in Hong Kong today.

Hong Kong Government delisted IRISL vessels 10 years ago.

Robert Clifton Burns, a former associate professor of law at Georgetown University Law Center who specializes in economic sanctions and is now in private practice, explains that the UN resolution makes it clear that member states are obligated to freeze assets whenever a company or person is named in an appendix to the resolution.

Robert Clifton Burns: I mean, member states are supposed to be responsible for freezing sanctions. If a sanctioned company is found to have possession or control of property or funds, then they need to freeze it and put it into a frozen account. For example, if Osama bin Laden were alive and he walked into McDonald’s and wanted to order a hamburger, it (McDonald’s) couldn’t give him a hamburger. If he offers you $5 for a burger, you can’t just refuse the deal and refuse to give him a burger, you can’t even give him his $5 back.

U.S. is keeping a close eye on Iranian companies in Hong Kong

Reuters reports that the Hong Kong government de-listed IRISL’s 19 Hong Kong-registered ships in 2012. But why are the companies associated with the 19 ships allowed to operate in Hong Kong today? The Hong Kong government has only indicated that the “1929 Resolution” sanctions have been terminated due to the IAEA report received by the UN Security Council in 2016, but has not responded to why no action was taken against IRISL affiliates in Hong Kong before 2016.

The United States has recently added a number of Iran-related sanctions to its list, many of them against Chinese or Hong Kong companies. Ross Feingold, a U.S.-based political risk management consultant, said in an interview that the U.S. is watching the behavior closely and that “it’s very difficult for a Chinese, Hong Kong or Iranian vessel to think that it can avoid U.S. attention in Hong Kong (by trading),” he said.

It will be interesting to see how the U.S. will view Hong Kong’s actions on the sanctions, and how it will feel that the degree of cooperation is not good enough, and that the Hong Kong government’s efforts are not good enough to draw more criticism from the U.S.,” said Fanger. Originally, the United States and Hong Kong had a good cooperative relationship in this regard, as long as the United States presented evidence, the (Hong Kong) relevant departments used to cooperate with, but now the Sino-US relations have deteriorated, the Hong Kong government and the United States relations have deteriorated, whether Hong Kong will cooperate with the United States is a political issue, previously it was a question of resources to combat. Especially now it’s just unilateral U.S. sanctions.

He added that since Hong Kong’s special status was revoked by the U.S. after the implementation of the National Security Law, the U.S.-Hong Kong relationship has deteriorated and the U.S. has “great opportunity to adjust the security level” as Hong Kong comes under full Chinese rule. At the same time, the Hong Kong government’s attitude toward the United States has also changed as a result of China’s strengthened governance.