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Rajah & Tann: “Black ships” of the Industry – US Sanctions and what they all mean

US sanctions have given rise to the Dark Web of Shipping and Covid-19 is likely to force shipowners to take unprecedented risks and supply to ‘black ships’, says Partner.

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Max Lim, a Partner of legal firm Rajah & Tann Singapore LLP, on Monday (7 September) provided marine fuel industry readers of Manifold Times a briefing on US sanctions of vessels, its side-effects in creating a black market, and future implications for the bunkering industry as these sanctions are expected to grow: 

“Black ships” of the Industry – US Sanctions and what they all mean

In recent times, the US has paid very close attention to the shipping industry, making no secret of its intention to intensify sanction measures.

At last check, there are 389 vessels on the American “blacklist”.

This “blacklist” is none other than the notorious SDN List (Specially Designated Nationals and Blocked Persons List) maintained by the US OFAC (Office of Foreign Assets Control).

Iran, the perennial target, tops the list with 202 vessels.

47 vessels have been marked for links to Venezuela (a relatively recent entrant).

102 are connected to North Korea. The remaining are spread amongst Cuba, Libya, Syria and Ukraine.

In terms of vessel-type, besides the obvious oil tankers, they comprise bulkers and containerships.

In my view, the vessel-count on this “blacklist” is expected to grow for 2 reasons.

With strengthened surveillance and intelligence, more vessels with ties to these sanctioned nations will be identified,

But more importantly, US sanctions have given rise to a shadow economy – the Dark Web of Shipping. The adage that with great risk comes great reward rings true. But not just that. The ongoing pandemic crisis is also likely to force shipowners and the like to walk down the road less travelled, to take up opportunities that very few would.

At the same time, these sanctioned nations have huddled together – if anything, out of necessity, having been forcibly excluded from the international mainstream. A good example of that symbiosis perhaps would be Iran and Venezuela. At opposite sides of the Atlantic, but the former desperate to export, and the latter in a desperate need of gasoline.

But what does this all mean?

For bunker players and the maritime sector as a whole here and elsewhere, it means having to tread very carefully.

Companies that supply to these “black ships” or deal with blacklisted entities run the clear risk of themselves being placed on the SDN “blacklist”.

A company that finds itself on the SDN list will undoubtedly face difficulty doing business as banks and other companies are likely to steer clear, for fear of being “blacklisted” themselves. Such is the cascading effect of US sanctions, which is at the heart of its efficacy.

At a practical level, funds tainted by association with a sanctioned entity (or even suspected of this), may end up being blocked or quarantined in the banking system for an extended period of time. Apart from the cumbersome process of having the funds released, it may also have an adverse impact on cash-flow.

The “long-arm” of US sanctions has a far-reaching effect, far beyond US soil.. The US however has seen fit to lay down the rules – its rules. Those who abide by the rules, may stay and continue playing. But for those who don’t, they are confined to the lowest division, with no chance of promotion.


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Published: 9 September, 2020

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Legal

Singapore withdraws remaining 127 charges against Hin Leong founder OK Lim

Lim Oon Kuin, also known as OK Lim, was issued a stern warning and a district court granted him a discharge amounting to an acquittal for these charges on 17 July.

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RESIZED Sora Shimazaki on Pexels

Founder of collapsed oil trader Hin Leong Trading, Lim Oon Kuin, also known as OK Lim, has had the remaining 127 charges against him withdrawn, according to The Straits Times on Monday (20 July). 

OK Lim was issued a stern warning and a district court granted him a discharge amounting to an acquittal for these charges, including those for cheating, on 17 July. The discharge means Lim cannot be prosecuted again for the same offences.

Lim, 84, is currently serving a 13½-year prison sentence after the High Court reduced his original 17½-year jail term in March 2026. He was convicted in 2024 on two cheating charges and one count of abetting forgery in a case prosecutors described as one of Singapore’s most serious trade finance frauds.

Lim was convicted in May 2024 of two charges of cheating the Hongkong and Shanghai Banking Corporation (HSBC) and one count of abetting forgery that proceeded to trial out of a total of 130 criminal charges.

He was first charged in court on 14 August 2020, and was subsequently handed further charges in court on 25 September 2020, 30 April 2021 and 24 June 2021 for his role in perpetuating fraud on various financial institutions. 

A total of 130 charges were eventually brought against him for cheating and forgery-related offences.

Related: Singapore: Hin Leong Founder OK Lim gets jail term slashed to 13.5 years

 

Photo credit: Sora Shimazaki
Published: 21 July, 2026

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Winding up

Singapore: Coastal Logistics Pte Ltd to be wound up voluntarily

Coastal Logistics was reportedly affiliated with troubled Singapore bunker player Coastal Oil (Singapore) Pte Ltd.

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RESIZED Drew Beamer

Several resolutions for Coastal Logistics Pte Ltd were made during an extraordinary general meeting held on 14 July, according to a notice in the Government Gazette on Friday (4 July).

The following resolutions were duly passed during the meeting:

As Special Resolution

  • That it has been proved to the satisfaction of the meeting that the Company cannot by reason of its liabilities continue its business and accordingly the Company be wound up voluntarily pursuant to Section 160(1)(b) of the Insolvency, Restructuring and Dissolution Act 2018 (No. 40 of 2018);

As Ordinary Resolutions

  • that Mr. Wong Pheng Cheong Martin and Ms. Koay May Yee, both care of FTI Consulting (Singapore) Pte Ltd, One Raffles Quay, #27-10 South Tower, Singapore 048583 be appointed as the joint and several Liquidators of the Company for the purpose of such winding up; and
  • that the Liquidators be at liberty to open, maintain and operate any bank account(s) or account(s) for monies received by them as Liquidators with such bank(s) as they deem fit; and
  • that a Committee of Inspection will not be formed.

Manifold Times previously reported Nicholas James Gronow, director of Heng Tong Fuels & Shipping and Coastal Logistics, filed statutory declarations for both companies stating the firms cannot continue their businesses due to liabilities.

Both companies were reportedly affiliated with troubled Singapore bunker player Coastal Oil (Singapore) Pte Ltd. 

In 2019, several vessels owned by both firms entered the sale & purchase (S&P) market in Singapore.

Related: Singapore: Director declares Heng Tong Fuels & Shipping’s inability to continue business
Related: Heng Tong Fuels & Shipping in court over DBS Bank bunker tanker loan
Related: Singapore: Bunker tanker “Coastal Neptune” arrested
Related: Heng Tong Fuels & Shipping, Coastal Logistics tankers enter S&P market

 

Photo credit: Drew Beamer
Published: 21 July, 2026

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Winding up

Singapore: Liquidator of Nan Shan Maritime Pte Ltd issues notice of dividend

Third interim dividend to admitted unsecured claims of Nan Shan Maritime is payable from 15 July, according to Government Gazette notice.

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RESIZED Drew Beamer

A notice of dividend for Nan Shan Maritime Pte Ltd, which is currently in creditors’ voluntary liquidation, was published on the Government Gazette on Wednesday (15 July). 

The following are the details of the notice:

Name of Company : Nan Shan Maritime (Pte.) Ltd.(In Creditors’ Voluntary Liquidation)
Unique Entity No. / Registration No. : 201701967H
Address of Registered Office : 10 Anson Road, #10-10, International Plaza, Singapore 079903
Amount per centum : 5.00 Per Centum of all admitted unsecured, claims
First and Final or Otherwise : Third Interim
When Payable : 15 July 2026
Where Payable : Entitlements will be made by way of cheque.

 

Photo credit: Drew Beamer
Published: 16 July, 2026

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