Libya is the programme on this site where the evasion is a commodity flow, not a corporate structure. The measure being evaded is less a ban on a counterparty than the rule about who may sell Libyan fuel and on whose behalf.
Two regimes
The UN regime is administered by a sanctions committee and monitored by a Panel of Experts established under resolution 1973 (2011). The Panel’s most recent final report, S/2024/914, covers 18 July 2023 to 25 October 2024 and was provided under resolution 2701 (2023).
The US programme rests on two executive orders. Under 31 CFR 570.201 it blocks the persons listed in the annex to E.O. 13566 of 25 February 2011 and persons determined under that order and under E.O. 13726, including those responsible for actions that threaten Libya’s peace, security or stability, “including through the supply of arms or related materiel”.
What the Panel documents
Fuel smuggling is the recurring subject. The Panel’s account is that national subsidies allow fuel to be imported at market rates and sold locally for a nominal sum, that the imported fuel, “predominantly diesel”, is then smuggled abroad and sold at black-market rates or at market rates with fake documentation, and that armed groups controlled the business and received a steady revenue stream from it (S/2024/914, para. 97).
On the maritime side, the Panel counted 137 visits by smuggling vessels to the old harbour at Benghazi during its reporting period, and 48 vessels making more than 185 visits between March 2022 and September 2024. It describes ship-to-ship loading in international waters, mostly off Malta, as the most used method, vessels sometimes untraceable for weeks, an estimated 1.125 million tons of diesel, and some illicit exports with international tenders and fake documentation (paras. 106–109). Naming the individual ships is vessel-level reference work that this site does not do; the Panel’s annexes identify them.
Why it belongs here
Two techniques this site describes appear in the Panel’s findings without any corporate layering: ship-to-ship transfers as the loading method and AIS gaps as the way vessels drop out of view. The Panel’s finding about documents matters for detection too: it says that limited understanding among industry actors of the legitimate process for exporting fuel from Libya contributed to an environment in which illicit exports could pass. A buyer or bank that does not know what a lawful Libyan fuel export looks like cannot tell it from an unlawful one.