Between November 2023 and June 2025, AEL purchased discounted LPG through a Dubai-based trader and caused over $192M in USD payments to be processed via the U.S. financial system, despite multiple red flags including suspicious pricing, falsified shipping documents, and vessel irregularities linked to Iran’s shadow oil network. OFAC found the violations egregious and reckless, noting that AEL failed to adequately investigate clear warning signs such as AIS manipulation, inconsistent cargo origin data, and unusually low pricing tied to Iranian supply chains…