UK shipping insurers are caught in Iran oil sanctions grey zone

Times

08-07-2025

A year before Marco Rubio was appointed President Trump's secretary of state, he wrote to the government of Panama urging it to investigate a number of oil tankers sailing under the country's flag.
The bipartisan letter, signed by Rubio and 21 other senators, included a list of ships that the group said had allegedly transported Iranian oil in violation of US sanctions. Unknown to the senators at the time, one of the tankers listed in the letter, Seafaith, had allegedly shipped Iranian petrochemicals while carrying insurance documents from the UK.
Seafaith had obtained an insurance policy from the West of England P&I Club (West), one of the twelve companies that cover most of the world's oceangoing ships against spills and accidents.
The vessel was one of three identified by The Times that held insurance documents from West while exporting oil or related products from Iran, in violation of US sanctions.
The Times identified four other ships that allegedly exported petrochemicals from Iran after obtaining insurance policies from another British shipping insurance syndicate, the UK P&I Club (UK P&I).
There is no suggestion that either UK P&I or West has violated sanctions themselves. In common with all big shipping insurers, neither syndicate insures any sanctioned activity. This means that the insurance club's provisions do not pay out if they were triggered while the policyholder was engaged in an activity subject to sanctions.
Furthermore, US sanctions on Iran are far more restrictive than those enacted by the UK, placing companies that might be subject to both regimes, given the potentially extremely broad application of US law, in a difficult situation. The US government can seek to claim jurisdiction over activity well outside its territory if it involves US dollars or touches the US financial system.
The UK also, in some cases, seeks to penalise UK entities that comply with US sanctions on Iran through 'blocking legislation' that the country adopted from the EU after Brexit.
Christopher Lock, an international trade partner at the law firm Sidley Austin, said that the legislation was an attempt to provide protection against the extra-territorial effects of US sanctions.
'In practice, these regulations cause compliance headaches for companies operating on both sides of the Atlantic,' he said. 'On the one hand, companies are faced with steep fines or even being sanctioned themselves for not complying with US sanctions. On the other hand, they risk either having their US compliance being challenged in European or British courts or, ultimately, criminal liability.'
Nonetheless, shipping insurers are an important part of the world's maritime industry, with internationally recognised proof of liability insurance against spills and accidents needed to enter most big ports.
The US Treasury seeks to place some burden on shipping insurers to monitor for suspicious behaviour through regular alerts and advisory notices, although it remains unclear who the US government considers primarily responsible for identifying suspicious tankers.
Both West and UK P&I said they were investigating the details of the sanctioned voyages provided to them by The Times.
UK P&I added that it used third-party tracking services to look out for suspicious ship behaviour, and regularly updated its members on sanctions rules and due diligence requirements, but that it was unable to monitor all of its members' operations in detail.
West said that it abided by all sanctions regimes and had robust compliance policies in place to ensure that its members complied with applicable sanctions regimes.
Charlie Brown, a senior adviser at United Against Nuclear Iran, an advocacy group based in the US, said that the recurrence of cases such as that of the Seafaith demonstrated gaps in the wider system of maritime due diligence.
'The appearance of vessels like Seafaith and others on the rosters of respected P&I clubs, despite their likely involvement in Iranian oil exports, illustrates the difficulty of fully policing Iran's global sanctions-evasion network,' Brown added.
Vessels carrying Iranian oil employ numerous tactics to evade scrutiny, often turning off location transponders or moving products via repeated ship-to-ship transfers in open waters.
Satellite imagery obtained by TankerTrackers.com, a company that specialises in monitoring the clandestine oil trade of Iran and other nations, detected one of these transfers between Cielo 1 and the US-sanctioned Hong Lu in March this year.
According to TankerTrackers, Hong Lu had loaded up with crude oil from Kharg Island, a small outcrop in the northern part of the Persian Gulf 16 miles off the coast of Iran, which doubles as the country's main oil and petrochemical terminal. Records from West and Kpler, a shipping data and analytics business, show that once loaded with roughly two million barrels of crude oil, Cielo 1 held insurance from West for at least part of its journey to China.
The vast majority, about 90 per cent, of Iran's oil exports ends up in small independent refineries in China.
In March the US sanctioned a number of these Chinese 'teapot' refineries and under Trump the US has taken a considerably more stringent position on Iran.
Along with oil, the US government has also turned its attention to Iran's petrochemical exports, under its campaign of 'maximum pressure' on Iran, which Trump imposed early in his administration. This policy culminated in the US bombing key nuclear sites in co-ordination with Israel last month.
Vessels exporting petrochemical products from Iran have also obtained insurance policies from British insurers. In November last year TankerTrackers spotted the vessel Swift Falcon calling at Kharg Island, where, according to Kpler, it took on roughly 100,000 barrels of naphtha, a petrochemical with a number of uses.
Swift Falcon had secured insurance documents from UK P&I during that voyage and 13 others that occurred between late October 2023 and May 2025, where records from Kpler show that it exported on average 290,000 barrels of naphtha from Iran on each voyage.
At least one ship insured by the UK P&I Club was also featured in a report published by the US Energy Information Administration, the statistical arm of the US Department of Energy, in October 2024. It was accused of being involved in the export and sale of Iranian petroleum and petroleum products.
According to Kpler, the vessel, which has been insured by the UK P&I Club since late August 2024, made six voyages from Iran to China while holding British insurance.