Nearly four years after the United States first sanctioned the Islamic Republic of Iran Shipping Lines (IRISL) and its fleet, the company appears to be struggling to stay afloat. In the latest sign that international pressure is having an impact, Irano Hind Shipping Company, a three-decade-old joint venture between IRISL and Shipping Corp of India, has been dissolved due to sanctions. And IRISL has been scrambling in recent months, setting up new front companies, dissolving others, swapping personnel, re-naming vessels, and re-flagging ships to increasingly unlikely locations.

The table below surveys the status of IRISL vessels blacklisted by the U.S. Treasury Department because of links to proliferation. It lists the current and previous names and flags for each of these 142 vessels, as well as their current owners, managers, and operators. The table reveals that vessels are now being re-flagged to unusual locations, like Moldova, Sierra Leone, and Tanzania.

A bill passed by the U.S. Congress on August 1 (which President Obama is expected to sign) should make it difficult for IRISL to obtain even these unlikely flags of convenience in the future. Among other things, the Iran Threat Reduction and Syria Human Rights Act penalizes any country that helps Iran evade sanctions by reflagging its vessels. This could put additional pressure on countries that have popped up in IRISL's latest round of ship re-flagging. Bolivia, which earlier this year briefly emerged as a flag of choice for IRISL vessels, has since de-flagged these ships. Malta too was once a popular flag of convenience for IRISL vessels; today none of the vessels on the blacklist are flying a Maltese flag.

Increasingly, countries appear to be revoking or refusing to flag vessels in which IRISL or its affiliates have an interest. As a result, IRISL may be operating vessels despite their flags having been revoked, according to guidance published on July 19 by the Treasury Department. The "Amin" is a good example. In late June, Sierra Leone revoked the flag for the Amin, an oil tanker which is operated by Irano Hind. That hasn't stopped the Amin from operating without a flag. On July 2 it called at Syria's Banias terminal. Syria has been a popular destination for IRISL vessels, for more than just oil. The United Nations has reported several incidents in recent years in which IRISL vessels were caught on their way to Syria loaded with arms and ammunition. Such arms exports, which came from entities linked to Iran's Ministry of Defense, are a violation of U.N. Security Council resolution 1747.

While many countries appear to have cut IRISL off, there are a few outliers. The Hong Kong flag is still flying on about twenty of IRISL's blacklisted vessels, and Hong Kong shell companies serve as the nominal owners of these vessels. Often, one or two IRISL vessels are the only assets held by these companies. IRISL's continued involvement is hardly a secret, as most of the vessels are operated and managed by well-known IRISL affiliates. All Hong Kong-flagged vessels are operated by Sapid Shipping Company and managed by Rahbaran Omid Darya. Both companies were created by IRISL in the wake of U.S. sanctions, to take over cargo and ship management operations, and both have been sanctioned by countries around the world. Today, these companies operate or manage about one third of IRISL's blacklisted vessels.

Surprisingly, Germany continues to host an IRISL agent that has been blacklisted by the United States and the European Union. According to its website, Hamburg-based Hanseatic Trade Trust operates fifteen vessels. All fifteen have been blacklisted by the United States, and all but one have been sanctioned by the European Union as well. These vessels are now flagged by Sierra Leone.

Still, European Union sanctions against IRISL have had an impact: whereas two years ago IRISL vessels had regular routes across Europe, today IRISL vessels are no longer welcome at European ports. They are still visiting ports in the Middle East, the Caspian, the eastern coast of Africa, and across Asia.

As new U.S. sanctions take effect, the ability of IRISL to operate should be further restricted. And the company will be forced to come up with increasingly deceptive ways to mask its presence. This is an indication that the sanctions applied by the European Union, the United States, and a number of other countries are preventing Iran's national carrier from continuing business as usual.

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The data in this table reflects the status of blacklisted IRISL vessels as of July 26, 2012.