Myanmar Sanctions Evasion: Regulator Orders Diesel Label for Iranian Jet Fuel

A letter from Myanmar’s foreign exchange regulator instructed importers to describe a sanctioned Iranian jet fuel delivery as diesel in official import records. The document, dated November 30, 2025, directed Dynamic Wave and its client to process payments for cargo that shipping data identified as jet fuel from Iran.

The paperwork discrepancy involved a shipment of approximately 113,000 barrels that arrived in Myanmar waters in December 2025. The tanker, named Reef and under US sanctions, carried fuel from the Iranian port of Bandar Abbas. However, the contract signed by Dynamic Wave, a Myanmar-based energy broker, described the cargo as South African diesel purchased from Thailand’s Tawan-Oil Trading for $15.8 million.

Data from the United Nations and the ship-to-ship transfer platform Vortexa showed no record of a South Africa to Myanmar diesel trade in 2025. Satellite imagery and analysis by SynMax Intelligence tracked the Reef’s route from Iran to Southeast Asia. The mismatch between the physical cargo and the contractual description formed the basis of the mislabeling scheme.

The need to disguise the cargo stems from US sanctions imposed on Myanmar’s jet-fuel industry in 2023. Washington cited the military’s bombing of civilian targets during the ongoing insurgency as the reason for the restrictions. Buying Iranian fuel also subjects buyers to broad American sanctions, creating a financial incentive to alter official records.

Myanmar’s regulatory authorities facilitated the change. The November 30 letter authorized Dynamic Wave and its client, National Energy Prime Aviation Services Company, to pay Tawan-Oil Trading. The letter stated the regulator would issue import papers describing the delivery as diesel instead of jet fuel, without providing a reason for the switch. National Energy Prime Aviation Services Company is part-owned by Myanmar’s military-backed government.

This incident follows a similar transaction in May 2025, where Dynamic Wave agreed to buy 202,000 barrels of purported South African diesel for $26 million. Jet-fuel expert Joshua Heyne of Washington State University noted that the fuel density in that invoice matched jet fuel rather than regional diesel. The price was also more than 50% above the global diesel benchmark. The tanker Noble delivered just under 200,000 barrels of jet fuel to Yangon on June 17, 2025.

The activist group Justice for Myanmar obtained the November letter from a junta-run server that was briefly accessible to the public. Reuters found a dead link to one of the files in search engine results, indicating it had been hosted on that server. Delivery dates and quantities in the documents align with Iranian shipment records reviewed by the news agency. The foreign exchange regulator’s action suggests official complicity in the relabeling process.

Myanmar’s foreign ministry stated in August that the military exercises maximum restraint to avoid civilian harm, despite UN reports of thousands killed in air attacks. The country’s generals seized power from the elected government of Aung San Suu Kyi in 2021, triggering a civil war. The continued flow of fuel supports both commercial flights and military air raids, while providing foreign currency to Iran. Dynamic Wave, Tawan-Oil Trading, and relevant banking authorities did not respond to requests for comment regarding the mismatched documents.