The best-documented AIS manipulation case in the enforcement record, and it is not a maritime case at all — it is an Indian conglomerate’s LPG purchasing file.
The transaction
In June 2023 Adani Enterprises entered the liquefied petroleum gas market. OFAC’s enforcement release records that it needed a discounted source, and in July 2023 met representatives of a Dubai-based trading company that was supplying purportedly Omani-origin LPG. An internal AEL document described the supplier as providing “discounted LPG from Middle East” on a spot basis.
The Dubai supplier “operated through a number of different affiliated entities.” In OFAC’s words, while it “represented itself as a reputable middleman supplying LPG primarily from Oman, as well as Iraq, in reality the company served as a conduit for illicit Iranian supply to enter the market.”
AEL went on to buy 35 cargoes. US financial institutions processed $192,104,044 across 32 shipments.
What the compliance checks did, and did not, do
This is the part worth studying, because AEL did the standard things. It ran know-your- customer verification on the supplier and its affiliates; it screened vessels, vessel operators and sellers against the SDN List; it reviewed shipping documentation and port-call lists. None of it produced a hit. OFAC records that “none of the parties involved in AEL’s LPG imports were sanctioned at the time” and “none of the documentation provided to AEL contained any information explicitly pointing to Iranian origin.”
That is the front company problem stated exactly. Screening tests whether a counterparty is listed. It does not test whether the counterparty is what it says it is.
The red flags OFAC says were there
The enforcement release enumerates them, and they map almost one to one onto the published maritime advisories.
Vessel behaviour. For the entire period, vessels carrying the supplier’s cargoes “routinely engaged in suspicious behavior, including (1) Automatic Identification System (AIS) manipulation, such as spoofing and prolonged unexplained AIS dark periods; (2) uneconomic or illogical vessel movements or port calls; and (3) frequent name, ownership, and flag state change.”
Geography that does not work. The first cargo was documented as loaded at Sohar, Oman. OFAC notes that Sohar “is not a significant source of Omani LPG exports, which originate primarily from Salalah,” and that facilities for exporting fully-refrigerated LPG “did not exist at Sohar at the time.” The claim was refuted by the port’s own capacity — the same reasoning the cargo origin page describes.
Documents that look manufactured. The paperwork bore “indica of falsification,” specifically “illogical and nonsequential numbering of certificates of origin,” “repeated unexplained delays in post-shipment issuance of documents,” and “use of outdated document templates.”
A price that was not commercially reasonable. Iran, OFAC observes, is “virtually alone among Middle Eastern sources of LPG” in offering significant discounts. Taking claimed origin, expected freight and reasonable port fees and margins together, the supplier’s prices “do not appear to have been commercially reasonable.”
Direct warnings. On at least four occasions between March 2023 and February 2024, AEL learned of third-party concerns that the supplier’s cargoes might be Iranian, including an inquiry from an Indian state-owned entity about a specific vessel. The vessel was accepted after checking documents that showed no explicit Iranian nexus. AEL later bought two cargoes, subsequently found to be Iranian, carried on that same vessel.
Why this case matters more than its size
Every indicator here was observable without privileged access. Transponder behaviour is broadcast. Port capacity is public. Freight rates are published. Document numbering is on the documents.
What defeated the checks was that they were run as list screening rather than as reconciliation. OFAC’s conclusion is that AEL’s programme “did not include other measures to account for risks arising from its dealings” — and it does not appear that AEL “took sufficient action in response to any of these red flags while the Apparent Violations were ongoing.”
The specific vessels, their transmission histories and their ownership and flag changes are vessel-level records, and this site does not carry them.