Agendas · MEF Policy Notes
Iran Pressure: Oil, Proxies and Money
How Iran keeps oil, weapons and cash moving to the Houthis and Hezbollah despite sanctions.
What the Notes Find
Iran kept exports around 1.5 to 1.8 million barrels per day into early 2026, and 217 of the 251 vessels it loaded with oil in 2025 had already been sanctioned for earlier voyages. (MEF-PN-2026-02) In September 2026 the Houthis took Mocha, Perim Island and the Hanish islands on the Bab el-Mandeb, with Iranian, Iraqi and Lebanese advisers named in documents on drones, missiles and intelligence. (MEF-PN-2026-04) Hezbollah’s financial network remains largely intact after Israel killed its top field commanders. (MEF-PN-2026-05) The shadow-fleet note finds that vessel designations hit ships while the registries, insurers and ports that service them remain a thinner target set; the oversight questions in all three notes test the same gap. (MEF-PN-2026-02)
Reading Order
1 of 3 · MEF-PN-2026-02
Iran’s Shadow Fleet and the Limits of Oil Sanctions
Iran kept oil moving through 2025 with a tanker network built to hide where its crude comes from.
Findings
- Core point: Iran kept exports around 1.5 to 1.8 million barrels per day into early 2026 despite renewed “maximum pressure,” with China buying the vast majority.
- The method: Ship-to-ship transfers, disabled transponders, false flags and forged papers relabel Iranian crude as Omani, Malaysian or Emirati.
- Repeat offenders: Of 251 vessels Iran loaded with oil in 2025, 217 had already been sanctioned for earlier illicit voyages.
- What changed: After U.S.-Israel operations began on February 28, 2026, loadings at Iranian terminals fell to 640,000 barrels per day in May.
- MEF analysis: Vessel designations hit ships; the registries, insurers and ports that service them are a thinner target set.
Questions for Oversight
- What does the figure of 217 previously sanctioned vessels among 251 loadings in 2025 imply about the deterrent effect of vessel designations alone?
- Which flag registries, including privately run registries, have been notified about tankers carrying Iranian crude, and what followed notification?
- What Treasury guidance covers insurers, bunkering ports and crew-change hubs outside the Gulf that service designated tankers?
- How does OFAC track renminbi settlement of Iranian crude purchases by Chinese independent refiners?
- What did the forfeiture of the Arina and Nostos cargoes yield, and how are forfeited proceeds used?
- How durable is the 2026 export decline if maritime pressure eases, given Iranian floating storage near Asian buyers?
2 of 3 · MEF-PN-2026-04
Houthi Attacks on Red Sea Shipping: From Campaign to Coastline
The Houthis have moved from firing at ships from inland highlands to holding the coast of the Bab el-Mandeb.
Findings
- Core point: In September 2026 the Houthis took Mocha, Perim Island and the Hanish islands, placing them on the Bab el-Mandeb.
- Why it matters: Nearly 15 percent of global trade transits the Bab el-Mandeb Strait.
- On the record: The State Department designated Ansarallah a Foreign Terrorist Organization by notice published March 5, 2025.
- Scale: A U.S. Maritime Administration advisory records more than 100 Houthi attacks on commercial vessels from November 2023 to October 2025.
- Supply chain: Documents reported by Jonathan Spyer name Iranian, Iraqi and Lebanese advisers on drones, missiles and intelligence.
Questions for Oversight
- How has the Foreign Terrorist Organization designation of Ansarallah affected transit payments to the Houthis, including those reported from Chinese carriers?
- What is the U.S. assessment of Houthi control of Perim Island and the Hanish islands for commercial traffic?
- How are interdictions of Iranian components bound for Saleef and Hodeidah tracked and reported to Congress?
- What did the March to May 2025 strikes show about the cost of U.S. munitions against low-cost Houthi systems?
- How does the State Department assess the Russian procurement links described in Treasury’s March 2025 designations?
- What does current Maritime Administration guidance advise for U.S.-flag and U.S.-owned vessels near the Bab el-Mandeb?
3 of 3 · MEF-PN-2026-05
Hezbollah’s Finance Networks After the War
Battlefield losses have not closed Hezbollah’s revenue lines.
Findings
- Core point: Hezbollah’s financial network remains largely intact even after Israel killed its top field commanders.
- On the record: Treasury’s February 10, 2026 action targeted a gold-for-cash front run under al-Qard al-Hassan and a shipping network routed through Turkey.
- Hemisphere reach: MEF’s Jose Lev Alvarez counts Treasury designations of “more than 100 Hezbollah-linked individuals and entities across at least ten Latin American countries over the past two decades.”
- Transit route: Mahan Air flew 11 Tehran to Beirut flights over Turkish airspace in the last weeks of 2024 after Syrian airspace closed.
- Handle with care: The often-cited figure of at least $200 million a year from the Tri-Border Area is an analysts’ estimate, not an audited total.
Questions for Oversight
- How has Treasury measured the effect of the February 2026 designations on al-Qard al-Hassan’s conversion of gold into cash?
- What action has Turkey taken on the Turkish-registered companies named in February 2026, and what has the United States requested?
- How are cash shipments on commercial flights into Beirut monitored with Lebanese authorities?
- Which Latin American governments share designation and financial-intelligence data with Treasury, and how is Brazil engaged?
- How does U.S. assistance to the Lebanese Armed Forces take account of Hezbollah’s remaining financial capacity?
- How do counternarcotics and terrorist-finance units coordinate on trade-based money laundering that benefits Hezbollah?
Bills Cited in These Notes
| Bill | Title | Cited In | Text and Status |
|---|---|---|---|
| H.R. 10076 | Lindsey O. Graham Sanctioning Russia and Iran Act of 2026 | MEF-PN-2026-02 | Congress.gov · Middle East Legislation in Congress |
| S. 3451 | Houthi Human Rights Accountability Act | MEF-PN-2026-04 | Congress.gov · Middle East Legislation in Congress |
| H.R. 10354 | To impose targeted sanctions on the Houthi terrorists and their supporters, and to support the internationally recognized Government of Yemen in their fight against Houthi terrorists. | MEF-PN-2026-04 | Congress.gov · Middle East Legislation in Congress |
| H.Res. 1379 | Condemning Lebanese Hezbollah's repeated violations of ceasefire agreements and calling for the Lebanese Government to ensure Lebanese Hezbollah immediately ceases all attacks and disarms, in accordance with the ceasefire. | MEF-PN-2026-05 | Congress.gov · Middle East Legislation in Congress |