Suez Rajan and Empire Navigation: Two Transfers, One False Cargo History

The Suez Rajan sanctions case exposed a scheme to hide Iranian oil behind a different ship’s cargo records. In the joint criminal statement supporting Suez Rajan Limited’s guilty plea and Empire Navigation’s deferred prosecution agreement, the companies admitted a plan to record two ship-to-ship transfers as one. The small loading would supply the paperwork for the much larger Iranian cargo. For a shipping insider, the revealing detail is who told the captain to change the records, what he objected to, and what the documents showed after they were corrected.

The Justice Department announced the case on September 8, 2023. Its account described both a corporate criminal case and a separate civil complaint alleging that the oil supported Iran’s Islamic Revolutionary Guard Corps.

Suez Rajan Limited Chartered the Vessel, Empire Navigation Operated It

Suez Rajan Limited was the bareboat charterer of the tanker. Empire Navigation operated it under a management agreement with Suez Rajan Limited. The joint statement of offense identifies a separate company as the vessel’s owner and another company as the time charterer arranging the cargo voyage to China.

That division matters because the instructions crossed company boundaries. The time charterer supplied the voyage instructions, while the captain worked at Empire’s direction. An Empire employee then told the captain how to record the loadings. A chartering employee and a shipboard officer could each see a different part of the same transaction.

In its guilty plea, Suez Rajan Limited admitted conspiring to violate the International Emergency Economic Powers Act and economic sanctions against Iran. Empire entered a deferred prosecution agreement.

How Suez Rajan and Empire Navigation Concealed Iranian Oil

The Iranian oil concealment scheme used a small cargo transfer to give a much larger shipment a false history. In the joint statement supporting the guilty plea and deferred prosecution agreement, both companies admitted the sequence of loadings, manipulated tracking and altered records described below.

The Iranian Loading Was Visible From Space

The oil arrived through the tanker Virgo. In January 2022, Virgo used a secondary automatic identification system transponder to broadcast a false position in the Persian Gulf. Satellite images showed the ship elsewhere, at Iran’s Kharg Oil Terminal.

The false AIS position could be compared with images of the physical vessel. The statement describes Virgo arriving empty and leaving fully loaded. Once it left Kharg, Virgo resumed its regular AIS transmission and headed toward the Strait of Malacca and the South China Sea.

To hide the Iranian loading, the participants also needed a different story in the receiving ship’s records.

The Small Transfer Supplied the Cover Story

The time charterer instructed Suez Rajan’s captain to load from CS Brilliance and then from another vessel. Before the Brilliance transfer, an Empire employee told the captain that both cargoes would be declared as a single loading from Brilliance. The vessel’s deck logbook, oil record book and other documents were all supposed to tell that story.

The captain said both operations should be recorded accurately. The Empire employee replied that the arrangement had been agreed between the time charterer and Empire.

Suez Rajan took on approximately 4,000 barrels from Brilliance near Malaysia in February 2022. Yet the draft depth it reported through AIS made the ship appear fully loaded. The statement of offense describes this as a ruse. The small transfer supplied an apparent loading event, and the reported draft made that event look large enough to explain the cargo.

When the captain objected that changing the reported draft could raise questions, the Empire employee told him Empire had done it before and that he could consult captains of other vessels. Falsifying the records was presented as routine.

The Larger Transfer Left Its Own Records

Virgo then transferred 976,483 barrels to Suez Rajan near Singapore. Satellite images showed the vessels alongside each other, and Suez Rajan’s logs recorded the loading. During the transfer, Virgo reported a position approximately eight miles away.

The captain also emailed loading records to addresses at both Empire and the time charterer. An attached activity log recorded that Suez Rajan had moored with Virgo and loaded from it. Those documents placed the Iranian cargo aboard the receiving tanker even though the original instruction was to attribute everything to Brilliance.

The Brilliance paperwork had its own contradiction. A vessel-log entry attributing a much larger cargo to Brilliance was crossed out and replaced by an entry recording a small loading. The captain’s protest letters also recorded that Brilliance had failed to provide certificates of quality, quantity and origin.

Around February 18, 2022, the Empire employee instructed the captain and chief officer to correct the oil record book to show the true quantities from both vessels. The captain sent draft changes to the employee for approval. Once the employee approved them, the captain instructed the chief officer to make the changes.

The same person who had instructed the captain to combine the loadings later approved separating them. The correction preserved more than a better cargo total. It showed the actual source of the oil and the operator’s role in deciding what the book would say.

The Charter Payments Brought the Voyage Into the U.S. Financial System

The chartering arrangement connected the cargo voyage to U.S.-dollar payments. The joint criminal statement records two charter-fee wires: $712,500 on February 11, 2022, and $516,234 on February 16, 2022. The time charterer sent those payments during the same month it directed the loadings.

The government’s separate civil complaint, as described in the Justice Department’s announcement, alleged that the charterer used the U.S. financial system to facilitate transportation of the Iranian oil.

The statement also records that the relevant entities had sought no licenses from the Treasury’s Office of Foreign Assets Control for the described financial transactions and ship-to-ship transfers before the investigation began. The payment leg and the cargo leg belonged to the same voyage.

A bank compliance officer may see the charter payments without seeing the captain’s loading emails. A chartering or accounting employee may understand what the payments bought. Set beside the voyage instructions and loading records, the charter agreement connects the money to the cargo whose origin the companies admitted concealing.

That is why an apparently ordinary charter payment deserves to be understood alongside the voyage instructions. The question for our experts is how what the payment represented compares with the loading that actually happened, and who inside the business knew the difference.

The Government’s Civil Claim Followed the Cargo

The government’s separate civil complaint alleged a scheme involving entities affiliated with the Islamic Revolutionary Guard Corps and its Quds Force to covertly sell and transport Iranian oil. It alleged that the oil facilitated money laundering and that profits from oil sales supported the Revolutionary Guard’s activities, including weapons proliferation, terrorism and human rights abuses.

What Are Examples of Sanctions Evasion?

False cargo origins, manipulated vessel tracking and rewritten loading records are examples of sanctions evasion documented in the companies’ criminal statement. Together they made oil from Iran appear to have come from a different source.

The same combination appears in the government’s separate civil complaint concerning the tanker Abyss, described in a February 2, 2024 announcement. Prosecutors alleged that Iranian fuel oil was made to appear Iraqi through manipulated AIS reporting and falsified documents. The recurring practice is a false origin supported by a matching account of the ship’s movements.

Hudson Institute’s 2021 report, Countering Global Kleptocracy: A New US Strategy for Fighting Authoritarian Corruption, describes the broader use of trade transactions to disguise criminal proceeds, including forged invoices that misrepresent the value of goods crossing borders. It explains why criminals turn toward commercial transactions:

In the Suez Rajan case, the admitted disguise concerned the oil’s origin. The trade-based money laundering perspective brings the commercial documents, physical movements and payments into the same inquiry. A cargo history can be false even when the cargo itself is very real.

What Shipping and Banking Insiders Can Add

A shipping insider can connect instructions to the records they changed. In this case, that connection runs from the time charterer’s voyage instructions through the Empire employee’s directions, the captain’s objections, the loading logs and the approved corrections. Satellite images showed where the ships were. The communications showed who wanted the paperwork to say something else.

A person in chartering may understand the contract and payment arrangements. An officer aboard the vessel may recognize the loading sequence and the changes to the oil record book. Someone in the operator’s office may know who received the captain’s emails and who approved the corrected entries. A banking insider may connect those operations to the charter payments.

FinCEN’s whistleblower program covers qualifying sanctions violations and provides for whistleblower awards. Our whistleblower experts help shipping and banking insiders connect what they know to the program that fits their evidence.

A separate whistleblower case under the False Claims Act can pay 15 to 30 percent of what the government recovers. For the sanctions conduct shown here, we assess the FinCEN route with you.

You Know the Voyage Behind the Payment

If you saw a loading disappear from the paperwork, a captain’s objection overruled or charter payments tied to a concealed cargo, speak to one of our Whistleblower Experts about what you know. We connect the voyage, the payments and the decisions inside the business to build your strongest sanctions whistleblower case. We bring in sanctions whistleblower lawyers who understand maritime trade and international payments, and stay with you from the first call through the case.