The Fuse

The Tale of Two Tankers and the Art of Sanctions Busting

by Noam Raydan | December 28, 2020

Five years ago, the United States sanctioned a liquefied petroleum gas (LPG) tanker for involvement in transferring LPG to the port of Baniyas in northwestern Syria. The American action was designed to weaken a network supplying Damascus with energy products—but the same vessel continues to visit Syria, with satellite imagery showing that the tanker was at Baniyas as recently as December 2020.

Some of the networks Washington sanctioned in 2015 have developed convoluted tactics to obfuscate their maritime activities and conceal their true ownerships, demonstrating their determination to evade sanctions in murky corners of the shipping industry where lawlessness pervades. The LPG tanker Melody (IMO 8800298) is one of many vessels that has continued to call on Syria despite U.S. and European sanctions.

Some of the networks Washington sanctioned in 2015 have developed convoluted tactics to obfuscate their maritime activities and conceal their true ownerships.

Romano-Baniyas Route
Recent ship tracking data and satellite imagery show that the Melody has been moving between Albania and Syria, most likely transferring LPG to Baniyas. Using satellite imagery,, an independent online service that tracks shipments and storage of crude oil, confirmed the presence of the LPG tanker at one of the berths in the port of Baniyas on December 3.

Satellite imagery showing the Melody in Syria on Dec 3, 2020, source: Sentinel Hub via

Before arriving at Baniyas, the Melody had been at the port of Romano in Durres, Albania, according to vessel tracking data from MarineTraffic. The tanker left the port around November 16, and by November 22 it was waiting off Dipkarpaz in Cyprus. The Melody turned off its AIS transponder later that day and went dark, a sign that it wanted to mask its Syrian destination. Twelve days later, the LPG tanker reappeared in the same location off Cyprus, according to MarineTraffic.

Map showing past track of Melody, Nov 2020-Dec 7,2020, Source: MarineTraffic

In 2015, the Melody was sailing under the name of Blue Way and was owned  by Milenyum Energy SA—a blacklisted entity involved in shipping energy products to Syria. Some traders are unaware of the final destinations of the products they sell: the U.S. Treasury accused certain officials at Milenyum of likely “misleading” in 2015 a Romanian petroleum supplier “to hide the Syrian end-user of a shipment of LPG.”

The Panama-registered company—which is also known as Milenyum Denizcilik Gemi and commonly referred to simply as “Milenyum”—operates in Turkey, and was designated by the U.S. Treasury for supplying Damascus with LPG and gasoil while using front companies to conceal the true ownership of the implicated vessels.

Two other blacklisted LPG tankers, also owned by Milenyum, were involved in a deadly accident in the Kerch Strait in 2019 during a Ship-to-Ship (STS) transfer of LPG while their AIS transponders were switched off. The two tankers, the Candy and Maestro, are also on the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) list of vessels engaged in STS transfers of petroleum destined for Syria. They too were owned by two companies that were most likely acting as front companies for Milenyum— Maestro Shipping Ltd and Milano Shipping Ltd—as a report by Deutsche Welle (DW) noted in September based on the leaked FinCen Files.

“When the AIS transponder goes off, there is generally something suspicious occurring.”

Navigational Behavior of High-Risk Tankers
The Melody’s navigational behavior is similar to that of other vessels which have been sailing to Syria while keeping their voyage details unknown or sending false data. “When the AIS transponder goes off, there is generally something suspicious occurring, as the AIS transponder is a critical piece of navigational safety equipment. Reputable transparent charterers, owners, managers, would not turn the transponders off,” said Wayne Hurley, head of Business Development at International Maritime Risk Rating Agency (IMRRA).

The Melody has a high-risk rating, according to IMRRA. Between 2015 and 2018, the LPG tanker changed its flag of convenience three times, switching between the flags of Mongolia, Tanzania, and Comoros, per the Equasis online shipping database. All three are blacklisted by the Paris Memorandum of Understanding—a 27-member organization whose mission is to eliminate the operation of sub-standard ships. “These are flags with a particularly weak record of enforcing international law,” noted Hurley.

The Melody—which is managed by NFS Shipping Inc, a company registered in Saint Kitts and Nevis—has changed its name at least three times since 2015, and has been called out by Ukrainian observers for violating western sanctions on Russian-annexed Crimea.

The Jaguar S
Shipping analysts have also spotted an oil tanker, the Jaguar S (IMO 9175169), sailing from the Romano port to Syria. The author of this piece was the first to report in October on a journey the tanker took in June to Baniyas, using vessel tracking data and satellite imagery provided by The vessel is believed to have picked up gasoline at the Romano port on May 15 before it ended up in Syria the following month. Prior to its voyage to Baniyas on June 4, with its AIS transponder switched off, the Jaguar S docked at the Mersin anchorage in Turkey.

In addition to its journey earlier this year from Romano, one Port State Control (PSC) report shows that in 2019 the Jaguar S was chartered by a company based at this Albanian port. On April 17, 2019, the Jaguar S was detained at the Greek port of Kali Limenes with 25 deficiencies. Its charterer was identified as AV International Group SH.A, based at Romano, according to a detention list published by the Paris Memorandum of Understanding. This company is formerly known as A&V-Gas Sh.a, an Albanian trader of LPG gas, according to This article, however, cannot claim the trader is involved directly or indirectly in shipment of energy products to Syria.

Long Way to Syria
The detention of the Jaguar S in late September at the Lebanese port of Zahrani for “illegally” entering Lebanese waters, drew attention to a tanker that in all likelihood wanted to remain under the radar. When the vessel was seen leaving Zahrani on December 1, local media outlet MTV questioned the legality of allowing the release of the Jaguar S with its gasoline cargo, saying it was in violation of regulations. Following its departure, the Jaguar S played a cat-and-mouse game on the waters to mask its Syrian destination, as reported by L’Orient Today.

The Jaguar S played a cat-and-mouse game on the waters to mask its Syrian destination.

Additional observations were made for this article using data from MarineTraffic. On December 4, the Jaguar S changed its destination from Dortyol, Turkey to Alexandria, Egypt—a fake destination that was used by the vessel to mask its brief journey to Syria. During a conversation on December 10 with Samir Madani, cofounder of, he confirmed that the Jaguar S was at the Baniyas anchorage on December 4, using satellite imagery. However, it was unclear if it discharged its cargo. The voyage of the Jaguar S afterwards reveals that the tanker’s business in the region was likely unfinished.

Later, on December 6, the tanker changed its destination to “To Order” and was waiting in an area off Cyprus. On December 15, the tanker still had its port of origin as Zahrani, but its destination changed to Mersin, Turkey, a port which the Jaguar S was seen calling on before, including in June before it went to Baniyas.

Satellite imagery showing the Jaguar S in Syria on Dec 21, 2020, source Sentinel Hub via

Finally, on December 18, the tanker departed Mersin while signaling yet again for an Egyptian port—this time Port Said—only to go dark and get caught again on December 21 by at Syria’s Baniyas.

Screenshot from MarineTraffic taken on December 18, 2020 showing the Jaguar S signaling for Port Said, Egypt

According to the Equasis online database, the registered owner of the Jaguar S is Jaguar Shipping LTD. The ship’s manager/commercial manager, meanwhile, is a company known as Dry Denizcilik Ve Gemi Islet, based in Istanbul, and with little information, if any, available on it.

“Smuggling and shipping is one of the world’s oldest professions, and many very talented people are able to hide the true management and ownership of a vessel,” said IMRRA’s Hurley.

As the Jaguar S remains in the dark, the LPG tanker, Melody, is now back in the region. On December 22—the day the U.S. Treasury issued new sanctions on the Syrian government—the Melody was seen off the Cypriot coast awaiting orders.

Map and data from MarineTraffic showing the Melody off Cyprus on Dec 22, 2020