104-468: Iraqi invasion of Iran (1980) Stalemate (1981) Iranian offensives to free Iranian territory (1981–82) Iranian offensives in Iraq (1982–84) Iranian offensives in Iraq (1985–87) Final stages (1988) Tanker War International incidents The tanker war , part of the larger Iran–Iraq War , was a series of military attacks by Iran and Iraq against merchant vessels in
208-460: A 2003 report by the Organisation for Economic Co-operation and Development (OECD) report entitled "Ownership and Control of Ships", these corporate structures are often multi-layered, spread across numerous jurisdictions, and make the beneficial owner "almost impenetrable" to law enforcement officials and taxation. The report concludes that "regardless of the reasons why the cloak of anonymity
312-481: A clever scheme to deter Iranian attacks against their shipping. They asked the United States if they could reflag Kuwaiti tankers as American and receive the protection of the U.S. Navy. The administration of President Ronald Reagan debated this idea but finally agreed to it on March 7, 1987." These are known to O'Rourke as "reflagged Kuwaiti ships". On 17 May 1987, 37 US sailors killed by an Iraqi attack on
416-692: A confrontation with Iran. Both sides had declared an "exclusion zone", meaning areas in which they had warned ships from entering. Iraq declared the area around Iran's Kharg Island to be an exclusion zone. Kharg Island hosted Iran's principal oil shipment port. Iraq gave precise definition, in coordinates, of this exclusion zone and gave advance notification to all countries. However, Iraq did not designate any safe passage routes in this zone. Iran declared all waters within 40 miles of its coast to be its exclusion zone. It instructed ships headed for non-Iranian ports to sail west of this line. While Iran also did not designate any safe passages in its exclusion zone, this
520-600: A crackdown to restore Saddam's control. The execution of Iraq's most senior Ayatollah, and "reports that Saddam's secret police had raped al-Sadr's sister in al-Sadr's presence, had set his beard alight, and then dispatched him with a nail gun" caused outrage throughout the Islamic world, especially among Iraqi Shias. The Shias' repeated calls for the overthrow of the Ba'ath party and the support they allegedly received from Iran's new government led Saddam to increasingly perceive Iran as
624-603: A full-scale invasion of Iran on 22 September 1980. The Iraqi Air Force launched surprise air strikes on ten Iranian airfields with the objective of destroying the Iranian Air Force , mimicking the Israeli Air Force in the Six-Day War . The attack failed to damage Iranian Air Force significantly: it damaged some of Iran's airbase infrastructure, but failed to destroy a significant number of aircraft:
728-660: A genuine link between a ship's owners and its flag state dates back to 1958, when Article 5(1) of the Geneva Convention on the High Seas also required that "the state must effectively exercise its jurisdiction and control in administrative, technical and social matters over ships flying its flag." The principle was repeated in Article 91 of the 1982 treaty called the United Nations Convention on
832-630: A global environment. In 2010 in a message connected to the World Maritime Day , the Secretary-General of the International Maritime Organization gave recognition to the present status of the open registries and noted that the seafarers from some developing countries are providing major source of foreign currency to their home economies: "The development of open registries for ships has given
936-444: A group of two or three low-flying F-4 Phantoms could hit targets almost anywhere in Iraq. Meanwhile, Iraqi air attacks on Iran were repulsed by Iran's F-14 Tomcat interceptor fighter jets, using Phoenix missiles , which downed a dozen of Iraq's Soviet-built fighters in the first two days of battle. The Iranian regular military, police forces, volunteer Basij, and Revolutionary Guards all conducted their operations separately; thus,
1040-573: A jurisdiction with measurement rules that reduced the certified gross register tonnage of a ship, to reduce subsequent port of call dock dues. Such was a consideration when Carnival Cruise Line changed the flag of the RMS Empress of Canada in 1972 to that of Panama. In 2011, Cunard Line registered all its ships in Bermuda , which, besides other considerations, enabled its ship captains to marry couples at sea. Weddings at sea are described as
1144-645: A large scale." Days before the Iraqi invasion and in the midst of rapidly escalating cross-border skirmishes, Iraqi military intelligence again reiterated on 14 September that "the enemy deployment organization does not indicate hostile intentions and appears to be taking on a more defensive mode." Iraq soon after expropriated the properties of 70,000 civilians believed to be of Iranian origin and expelled them from its territory. Many, if not most, of those expelled were in fact Arabic-speaking Iraqi Shias who had little to no family ties with Iran. This caused tensions between
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#17327730594551248-427: A lucrative market. Maritime industry practitioners and seafarers from other countries contend that this is a natural product of globalisation. Supporters of the practice, however, point to economic and regulatory advantages, and increased freedom in choosing employees from an international labour pool. Publications from as early as 1962 argue that shipowners from developed countries use the practice to be competitive in
1352-695: A means of avoiding labor regulation in the country of ownership, and become a vehicle for paying low wages and forcing long hours of work and unsafe working conditions. Since FOC ships have no real nationality, they are beyond the reach of any single national seafarers' trade union." They also say that these ships have low safety standards and no construction requirements, that they "do not enforce safety standards, minimum social standards or trade union rights for seafarers", that they frequently fail to pay their crews, have poor safety records, and engage in practices such as abandoning crewmen in distant ports. While flag of convenience ships have been involved with some of
1456-411: A neutral, unintentionally into war. The Liberian open registry, founded in 1948, was the brainchild of Edward Stettinius , who had been Franklin D. Roosevelt 's Secretary of State during World War II. Stettinius created a corporate structure that included The Liberia Corporation , a joint-venture with the government of Liberia. The corporation was structured so that 25% of its revenue would go to
1560-416: A nominee director to divulge the identity of beneficial owners. A further hurdle is that some jurisdictions allow a corporation to be named as a director. Flag of convenience ships have long been linked to crime on the high seas. For example, in 1982, Honduras shut down its open registry operations because it had enabled "illegal traffic of all kinds and had given Honduras a bad name". Ships registered by
1664-413: A nominee to be the shareholder, and that nominee cannot legally be compelled to reveal the identity of the beneficial owner. All corporations are required to have at least one director, however many jurisdictions allow this to be a nominee director. A nominee director's name would appear on all corporate paperwork in place of the beneficial owners, and like nominee shareholders, few jurisdictions can compel
1768-690: A pretext. A successful invasion of Iran would enlarge Iraq's petroleum reserves and make Iraq the region's dominant power. With Iran engulfed in chaos, an opportunity for Iraq to annex the oil-rich Khuzestan Province materialized. In addition, Khuzestan's large ethnic Arab population would allow Saddam to pose as a liberator for Arabs from Persian rule. Fellow Gulf states such as Saudi Arabia and Kuwait (despite being hostile to Iraq) encouraged Iraq to attack, as they feared that an Islamic revolution would take place within their own borders. Certain Iranian exiles also helped convince Saddam that if he invaded,
1872-518: A result, flags of convenience perpetuate IUU fishing which has extensive environmental, social and economic impacts, particularly in developing countries. The EJF is campaigning to end the granting of flags of convenience to fishing vessels as an effective measure to combat IUU fishing. According to Franz Fischler , European Union Fisheries Commissioner , The practice of flags of convenience, where owners register vessels in countries other than their own in order to avoid binding regulations or controls,
1976-534: A ship, the port state may take actions including detaining the ship . In 2015, member states of the Paris MOU conducted 17,858 inspections with deficiencies, which resulted in 595 detained vessels and 11 banned. Member states of the Tokyo Memorandum of Understanding conducted 17,269 ship inspections in 2015, recording 83,606 deficiencies which resulted in 1,153 detentions. The principle that there be
2080-535: A threat that, if ignored, might one day overthrow him; he thus used the attacks as pretext for attacking Iran that September, though skirmishes along the Iran–Iraq border had already become a daily event by May that year. Despite Iran's bellicose rhetoric, Iraqi military intelligence reported in July 1980 that "it is clear that, at present, Iran has no power to launch wide offensive operations against Iraq, or to defend on
2184-411: A total of 1,041,986,000 DWT : more than 46% of the world's shipborne carrying capacity. The following table gives the distribution between the 10 largest world registries in terms of tonnage (millions dwt): Source: UNCTAD (estimates based on data supplied by Clarkson Research Services ). The data refer to the beginning of an indicated year. In comparison, the total capacity of ships in
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#17327730594552288-531: A weakened Iran's consolidation of the Islamic Revolution , forcibly reclaimed territories in Zain al-Qaws and Saïf Saad ; these had been promised to Iraq under the terms of the 1975 Algiers Agreement , but were never actually transferred. Both Iran and Iraq later declared the treaty as null and void, doing so on 14 September and 17 September, respectively. As a result, the only outstanding dispute along
2392-461: A whole. The Iraqi government sought to take control of the entire Shatt al-Arab in a rapid and decisive military campaign, believing that Iraq's victory in the broader conflict would humiliate Iran and lead to Khomeini's downfall, or, at the very least, thwart the new Iranian government's attempts to spread Khomeinism throughout the Muslim world . Saddam had also aspired to annex Khuzestan and saw
2496-656: Is a serious menace to today's maritime world. In 1978, a number of European countries agreed in The Hague to audit labour conditions on board vessels vis-a-vis the rules of the International Labour Organization . To this end, in 1982 the " Paris Memorandum of Understanding on Port State Control " (Paris MOU) was established, setting port state control standards for what is now twenty-six European countries and Canada. Several other regional Memoranda of Understanding have been established based on
2600-452: Is its flag state , and the flag state gives the ship the right to fly its civil ensign. A ship operates under the laws of its flag state, and these laws are used if the ship is involved in an admiralty case. A ship's flag state exercises regulatory control over the vessel and is required to inspect it regularly, certify the ship's equipment and crew, and issue safety and pollution prevention documents. The organization which actually registers
2704-427: Is made available, if it is provided it will also assist those who may wish to remain hidden because they engage in illegal or criminal activities, including terrorists." The OECD report concludes that the use of bearer shares is "perhaps the single most important (and perhaps the most widely used) mechanism" to protect the anonymity of a ship's beneficial owner. Physically possessing a bearer share accords ownership of
2808-587: Is not our concern." Less than two years later, French forces seized the Cambodian-flagged, Greek-owned MV Winner for cocaine smuggling. Shortly after the seizure, Cambodian Prime Minister Hun Sen closed the registry to foreign ships, and Cambodia canceled its contract with CSC shortly thereafter. The North Korean flag of convenience has also garnered significant scrutiny. In 2003, the North Korean freighter Pong Su reflagged to Tuvalu in
2912-865: Is often described as an open registry . Panama, for example, offers advantages such as easier registration (often online), the ability to employ cheaper foreign labour, and an exemption on income taxes. The modern practice of ships being registered in a foreign country began in the 1920s in the United States when shipowners seeking to serve alcohol to passengers during Prohibition registered their ships in Panama. Owners soon began to perceive advantages in terms of avoiding increased regulations and rising labor costs and continued to register their ships in Panama even after Prohibition ended. The use of open registries steadily increased, and in 1968, Liberia grew to surpass
3016-419: Is often used pejoratively, and although common, the practice is sometimes regarded as contentious. Each merchant ship is required by international law to be registered in a registry created by a country, and a ship is subject to the laws of that country, which are used also if the ship is involved in a case under admiralty law . A ship's owners may elect to register a ship in a foreign country so as to avoid
3120-567: Is that shipowners who want to hide their ownership may select a flag-of-convenience jurisdiction which enables them to be legally anonymous. Some ships with flags of convenience have been found engaging in crime, offering substandard working conditions, and negatively impacting the environment, primarily through illegal, unreported and unregulated fishing . Prior to the implementation of the International Convention on Tonnage Measurement of Ships, 1969 , shipowners may have selected
3224-506: The ITF says: Arms smuggling, the ability to conceal large sums of money, trafficking in goods and people and other illegal activities can also thrive in the unregulated havens which the flag of convenience system provides. Panama has the largest maritime register, followed by Liberia. Landlocked Mongolia also has a major registry, as does Bolivia. Also, some registers are based in other countries. For example, Panamanian overseas consulates manage
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3328-590: The Iran–Iraq War , and lasted until 5 December 1980. Ba'athist Iraq believed that Iran would not respond effectively due to internal socio-political turmoil caused by the country's Islamic Revolution one year earlier. However, Iraqi troops faced fierce Iranian resistance, which stalled their advance into western Iran . In two months, the invasion came to a halt after Iraq occupied more than 25,900 square kilometres (10,000 sq mi) of Iranian territory. On 10 September 1980, Iraq, hoping to take advantage of
3432-503: The Iran–Iraq border at the time of the Iraqi invasion on 22 September was the question of whether Iranian ships would fly Iraqi flags and pay navigation fees to Iraq while sailing through a stretch of the Shatt al-Arab spanning several kilometres. On 22 September, Iraqi aircraft pre-emptively bombarded ten Iranian airfields in an ultimately unsuccessful attempt to gain aerial superiority on
3536-512: The Iraqis and Arabs everywhere, we tell those Persian cowards and dwarfs who try to avenge al-Qadisiyah that the spirit of al-Qadisiyah as well as the blood and honor of the people of al-Qadisiyah who carried the message on their spearheads are greater than their attempts. In 1979–1980, anti-Ba'ath riots arose in the Iraq's Shia areas by groups who were working toward an Islamic revolution in their country. Saddam and his deputies believed that
3640-623: The Islamic Dawa Party a capital offense at the end of March, Shia militants assassinated 20 Ba'ath officials, and Deputy Prime Minister Tariq Aziz was almost assassinated on 1 April; Aziz survived, but 11 students were killed in the attack. Three days later, the funeral procession being held to bury the students was bombed. Iraqi Information Minister Latif Nusseif al-Jasim also barely survived assassination by Shia militants. In April 1980, Grand Ayatollah Muhammad Baqir al-Sadr and his sister Amina al-Sadr were executed as part of
3744-535: The Muslim conquest of Persia while promoting his country's position against Iran in the context of a looming war. On 2 April 1980, during a visit to al-Mustansiriya University in the city of Baghdad , he drew parallels to the 7th-century Battle of al-Qadisiyyah , in which the Rashidun Caliphate secured a decisive victory over the Sasanian Empire : In your name, brothers, and on behalf of
3848-490: The Osirak nuclear reactor near Baghdad. By 1 October, Baghdad had been subjected to eight air attacks. In response, Iraq launched aerial strikes against Iranian targets. The people of Iran, rather than turning against their still-weak Islamic Republic, rallied around their country. An estimated 200,000 fresh troops had arrived at the front by November, many of them ideologically committed volunteers. Though Khorramshahr
3952-626: The Persian Gulf and Strait of Hormuz from 1981 to 1988. Iraq was responsible for 283 attacks while Iran accounted for 168. The Iran-Iraq war began in September 1980. Before 1984, attacks against shipping had occurred, albeit on a much smaller scale. In December 1980, UN Secretary General Kurt Waldheim appealed to Iran and Iraq to ensure the security of peaceful shipping in the Gulf. At that time, Iran assured other countries that it would keep
4056-505: The Strait of Hormuz open. In his 1988 review paper O'Rouke wrote that "Iran trapped or destroyed many Iraqi ships in port in the early stages of the war. But Iraq started the tanker war in the Gulf proper in 1981 by initiating attacks on ships steaming to or from Iranian ports at the extreme northern end of the Gulf. Iraq continued these attacks into 1984 without a parallel Iranian response at sea. In March of that year, however, Iraq increased
4160-555: The USS Stark . United Nations Security Council Resolution 598 , was adopted unanimously on 20 July 1987, which engendered Operation Earnest Will (24 July 1987 – 26 September 1988), a successful US effort to protect Kuwaiti merchandise and vessel, because as noted by O'Rourke: "Aside from Iranian shipping, the most frequent victims have been ships steaming under the world's predominant flags of convenience ." Western-led convoy tactics with armed guard vessels were used for protection in
4264-932: The United Kingdom with the world's largest ship register. Traditional maritime nations, mainly from Europe, responded to this practice with creation of so called " second registers " - open registries, using national flags or flags of semi-sovereign offshore dependencies. That process begun in 1984 with the Isle of Man registry created as a second UK register. Soon after Norway and the Netherlands followed this practice adopting Netherlands Antiles and Norwegian International Ship Register (NIS) respectively. France established in 1989 Kerguelen Islands Register (replaced by International French Register ( Registre International Français - RIF in 2005 ) and Germany (Federal Republic of) created German International Register (GIS) in
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4368-759: The pan-Arabism espoused by Iraq's Ba'athists. Saddam's primary interest in war may have stemmed from his desire to right the supposed "wrong" of the Algiers Agreement , in addition to finally achieving his desire of annexing Khuzestan and becoming the regional superpower. Saddam's goal was to replace Egypt as the "leader of the Arab world" and to achieve hegemony over the Persian Gulf. He saw Iran's increased weakness due to revolution, sanctions, and international isolation. Saddam had invested heavily in Iraq's military, buying large amounts of weaponry from
4472-484: The "degree of ratification and enforcement of ILO Conventions and Recommendations," and "safety and environmental record". As of August 2024 , the list includes 43 registries. As of 1 January 2024 , Liberia, Panama and the Marshall Islands are the world's three largest registries in terms of deadweight tonnage (DWT). These three nations registered 17,752 ships of 1,000 DWT and above, for
4576-438: The 1975 Algiers Agreement null and void... This river [Shatt al-Arab]...must have its Iraqi-Arab identity restored as it was throughout history in name and in reality with all the disposal rights emanating from full sovereignty over the river...We in no way wish to launch war against Iran. Despite Saddam's claim that Iraq did not want war with Iran, the next day his forces proceeded to attack Iranian border posts in preparation for
4680-418: The 1982 Paris Memorandum of Understanding on Port State Control or Paris MOU. Under port state control , ships in international trade became subject to inspection by the states they visit. In addition to shipboard living and working conditions, these inspections cover items concerning the safety of life at sea and the prevention of pollution by ships. In cases when a port state inspection uncovers problems with
4784-658: The American company SeaLand 's fleet of 63 ships were foreign-flagged, saving the company up to US$ 3.5 million per ship every year. The environmental disaster caused by the 1978 sinking of the MV ; Amoco Cadiz , which flew the Liberian flag, spurred the creation of a new type of maritime enforcement. Resulting from strong political and public outcry over the Amoco Cadiz sinking, fourteen European nations signed
4888-722: The Arab revolts, the Revolutionary Guards would be drawn out of Tehran, leading to a counter-revolution in Iran that would cause Khomeini's government to collapse and thus ensure Iraqi victory. However, rather than turning against the revolutionary government as experts had predicted, Iran's people (including Iranian Arabs) rallied in support of the country and put up a stiff resistance. By September, skirmishes between Iran and Iraq were increasing in number. Iraq began to grow bolder, both shelling and launching border incursions into disputed territories . Malovany describes
4992-650: The Cambodia Shipping Corporation (CSC) were found smuggling drugs and cigarettes in Europe, breaking the Iraq oil embargo, and engaging in human trafficking and prostitution in Europe and Asia. In response to these activities, in 2000, Ahmad Yahya of the Cambodian Ministry of Public Works and Transport told industry publication Fairplay "We don't know or care who owns the ships or whether they're doing 'white' or 'black' business ... it
5096-509: The FOC flag states lack the resources or the will to properly monitor and control those vessels. The Environmental Justice Foundation (EJF) contends that illegal, unreported and unregulated fishing (IUU) vessels use flags of convenience to avoid fisheries regulations and controls. Flags of convenience help reduce the operating costs associated with illegal fishing methods, and help illegal operators avoid prosecution and hide beneficial ownership. As
5200-492: The Iraqi Air Force was only able to strike in depth with a few MiG-23BN , Tu-22 , and Su-20 aircraft. Three MiG-23s managed to attack Tehran, striking its airport , but destroyed only a few aircraft. The next day, Iraq launched a ground invasion along a front measuring 644 km (400 mi) in three simultaneous attacks. Of Iraq's six divisions that were invading by ground, four were sent to Khuzestan, which
5304-510: The Iraqi Army had "liberated" all disputed territories within Iran. It should be carefully noted that Malovany, an Israeli ex-intelligence analyst writing years later, said the enclaves were not completely seized until 21 September. With the conclusion of the "liberating operations", on 17 September, in a statement addressed to Iraq's parliament, Saddam stated: The frequent and blatant Iranian violations of Iraqi sovereignty...have rendered
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#17327730594555408-573: The Iraqi Army's seizure of the Zayn al-Qaws enclave, near Khanaqin (by 6th Armoured Division , 2nd Corps); the Saif Sa'ad enclave ( 10th Armoured Division ) and the Maysan enclave between Shib and Fakkeh ( 1st Mechanised Division , 3rd Corps). Iran responded by shelling several Iraqi border towns and posts, though this did little to alter the situation on the ground. By 10 September, Saddam declared that
5512-614: The Iraqi invading forces did not face coordinated resistance. However, on 24 September, the Iranian Navy attacked Basra, Iraq , destroying two oil terminals near the Iraqi port Faw , which reduced Iraq's ability to export oil. The Iranian ground forces (primarily consisting of the Revolutionary Guard) retreated to the cities, where they set up defences against the invaders. On 30 September, Iran's air force launched Operation Scorch Sword , striking and badly damaging
5616-952: The Iraqis were repelled. On 14 October, the Iraqis launched a second offensive. The Iranians launched a controlled withdrawal from the city, street by street. By 24 October, most of the city was captured, and the Iranians evacuated across the Karun River . Some partisans remained, and fighting continued until 10 November. Though the Iraqi air invasion surprised the Iranians, the Iranian air force retaliated with an attack against Iraqi military bases and infrastructure in Operation Kaman 99 ( Bow 99). Groups of F-4 Phantom and F-5 Tiger fighter jets attacked targets throughout Iraq, such as oil facilities, dams, petrochemical plants, and oil refineries, and included Mosul Airbase , Baghdad , and
5720-456: The Islamic Revolution as an opportunity to do so, seeking to increase his country's prestige and power in the Arab world. To this end, his administration hoped that Iraq, as an Arab-majority country, could successfully exploit Arab separatism in Khuzestan to undermine Iran from within. In practice, these objectives failed to materialize and the majority of Iranian Arabs were indifferent to
5824-524: The Kirkuk oil refinery. Iraq was taken by surprise at the strength of the retaliation, as Iran took few losses while the Iraqis took heavy defeats and economic disruption. The Iranian force of AH-1J SeaCobra helicopter gunships began attacks on the advancing Iraqi divisions, along with F-4 Phantoms armed with Maverick missiles ; they destroyed numerous armoured vehicles and impeded the Iraqi advance, though not completely halting it. Iran had discovered that
5928-613: The Law of the Sea and often referred to as UNCLOS. In 1986, the United Nations Conference on Trade and Development attempted to solidify the genuine link concept in the United Nations Convention on Conditions for Registration of Ships . The Convention for Registration of Ships would require that a flag state be linked to its ships either by having an economic stake in the ownership of its ships or by providing mariners to crew
6032-537: The Liberian government, another 10% went to fund social programs in Liberia, and the remainder returned to Stettinius' corporation. The Liberian registry was created at a time when Panama's registry was becoming less attractive for several reasons including its unpopularity with the U.S. labor movement and European shipping concerns, political unrest in Panama, and increases in its fees and regulations. On 11 March 1949, Greek shipping magnate Stavros Niarchos registered
6136-877: The Paris model, including the " Memorandum of Understanding on Port State Control in the Asia-Pacific Region ", typically referred to as the "Tokyo MOU", and organizations for the Black Sea, the Caribbean, the Indian Ocean, the Mediterranean, and Latin America. The Tokyo and Paris organizations generate, based on deficiencies and detentions, black-, white-, and grey-lists of flag states. The US Coast Guard , which handles port state control inspections in
6240-513: The Seamen's Act, Panamanian-flagged ships in this early period paid sailors on the Japanese wage scale, which was much lower than that of western merchant powers. In the early phase of World War II the transfer of American-owned ships to the Panama registry was sanctioned by the United States government so that they could be used to deliver materials to Britain without dragging the United States, as
6344-487: The Soviet Union and France. Between 1973 and 1980 alone, Iraq purchased an estimated 1,600 tanks and APCs and over 200 Soviet-made aircraft. By 1980, Iraq possessed 242,000 soldiers (second only to Egypt in the Arab world), 2,350 tanks and 340 combat aircraft. Watching the powerful Iranian army that frustrated him in 1974–1975 disintegrate, he saw an opportunity to attack, using the threat of Islamic Revolution as
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#17327730594556448-403: The U.S. and U.K. registers as of 1 January 2024 is 13.2 mil. dwt and 11.1 mil. dwt respectively. There are a number of common threads found in criticisms of the flag of convenience system. One is that these flag states have insufficient regulations and that those regulations they do have are poorly enforced. Another is that, in many cases, the flag state cannot identify a shipowner, much less hold
6552-577: The US, maintains a similar target list for underperforming flag states. As of August 2024 , it could be said that the 6 major FOC registries in terms of tonnage (representing more than half of the world tonnage) are performing pretty well in respect of PSC inspections: tonnage Sources: International Chamber of Shipping (ICS) , Paris MoU , Tokyo MoU , USCG Both Paris and Tokyo MoU-s maintain black lists of low performing flags, but there are FOC and non-FOC registries among them. Panama has
6656-718: The United States to strengthen the United States Merchant Marine and provide safeguards for its mariners. During this period, U.S.-flagged ships became subject to regular inspections undertaken by the American Bureau of Shipping . This was also the time of Robert LaFollette 's Seamen's Act of 1915 , which has been described as the " Magna Carta of American sailors' rights". The Seamen's Act regulated mariners' working hours, their payment, and established baseline requirements for shipboard food. It also reduced penalties for disobedience and abolished
6760-500: The battlefield. On the next day, Iraqi troops crossed the international border in strength and advanced into Iran in three simultaneous thrusts along a front of approximately 644 kilometres (400 mi). Of Iraq's six divisions that were invading by land, four were sent to Iran's oil-rich Khuzestan in order to cut off Iranian access to the Shatt al-Arab and establish a territorial security zone. Iraqi president Saddam Hussein presented
6864-567: The central front, the Iraqis occupied Mehran , advanced towards the foothills of the Zagros Mountains , and were able to block the traditional Tehran–Baghdad invasion route by securing territory forward of Qasr-e Shirin, Iran . Two of the four Iraqi divisions which invaded Khuzestan, one mechanised and one armoured, operated near the southern end and began a siege of the strategically important port cities of Abadan and Khorramshahr . The other two divisions, both armoured, secured
6968-608: The civil war of 1990, Liberia joined with the Republic of the Marshall Islands to develop a new maritime and corporate program. The resulting company, International Registries , was formed as a parent company, and in 1993 was bought out by its management. After taking over the Liberian government, Americo-Liberian warlord Charles Taylor signed a new registry contract with the Liberian International Ship and Corporate Registry , commonly known as LISCR. LISCR
7072-431: The corporation. There is no requirement for reporting the transfer of bearer shares, and not every jurisdiction requires that their serial numbers even be recorded. Two similar techniques to provide anonymity for a ship's beneficial owner are "nominee shareholders" and " nominee directors ". In some jurisdictions that require shareholder identities to be reported, a loophole may exist where the beneficial owner may appoint
7176-647: The crew compartments of their target ships." Iran also used Chinese-made shore-based Silkworm missiles to good effect. Iraqi invasion of Iran lraqi short-term operational success [REDACTED] Iranian Armed Forces [REDACTED] Iraqi Armed Forces Iraqi invasion of Iran (1980) Stalemate (1981) Iranian offensives to free Iranian territory (1981–82) Iranian offensives in Iraq (1982–84) Iranian offensives in Iraq (1985–87) Final stages (1988) Tanker War International incidents The Iraqi invasion of Iran began on 22 September 1980, sparking
7280-610: The documentation and collect registration fees, Liberia's registry is managed by a company in Virginia and Bahamas' from the City of London. A ship's beneficial owner is legally and financially responsible for the ship and its activities. For any of a number of reasons, some justifiable and some suspicious, shipowners who wish to conceal their ownership may use a number of strategies to achieve that goal. In jurisdictions that permit it, actual owners may establish shell corporations to be
7384-400: The end of 1980, Iraq had destroyed about 500 Western -built Iranian tanks and captured 100 others. Flags of convenience Flag of convenience ( FOC ) is a business practice whereby a ship's owners register a merchant ship in a ship register of a country other than that of the ship's owners, and the ship flies the civil ensign of that country, called the flag state . The term
7488-503: The entire world fleet by deadweight tonnage , maintaining roughly the same proportion for over a decade. The International Transport Workers' Federation (ITF) is the biggest campaigner against FOC since 1948, and maintains a list of registries it considers to be flags of convenience. In developing the list, the ITF takes into account "ability and willingness of the flag state to enforce international minimum social standards on its vessels,"
7592-593: The fighting around Susangerd. On 22 September, a prolonged battle began in the city of Khorramshahr, eventually leaving 7,000 dead on each side. Reflecting the bloody nature of the struggle, Iranians came to call Khorramshahr "City of Blood" ( خونین شهر , Khunin shahr ). The battle began with Iraqi air raids against key points and mechanised divisions advancing on the city in a crescent-like formation. They were slowed by Iranian air attacks and Revolutionary Guard troops with recoilless rifles , rocket-propelled grenades , and Molotov cocktails . The Iranians flooded
7696-619: The first ship under the Liberian flag, World Peace . When Stettinius died in 1949, ownership of the registry passed to the International Bank of Washington , led by General George Olmsted . Within 18 years, Liberia grew to surpass the United Kingdom as the world's largest register. Due to Liberia's 1989 and 1999 civil wars , its registry eventually fell second to Panama's flag of convenience, but maritime funds continued to supply 70% of its total government revenue. After
7800-738: The flag of the fledgling United States quickly found it offered little protection against attack by Barbary pirates – many responded by seeking to transfer their registry back to Great Britain. The use of false flags was frequently used as a ruse de guerre by the British during the Napoleonic Wars and the United States during the War of 1812 . During the mid-19th century, slave ships flew various flags to avoid being searched by British anti-slavery fleets . The Belen Quezada , in August 1919,
7904-462: The fledgling Islamic republic would quickly collapse. In particular, Saddam was assured of Saudi support for an invasion of Iran during his August 1980 visit to Saudi Arabia. In 1979–1980, Iraq was the beneficiary of an oil boom that saw it take in US$ 33 ;billion, which allowed the government to invest heavily in both civilian and military projects. On several occasions, Saddam alluded to
8008-759: The highest-profile oil spills in history (such as the Maltese-flagged MV ; Erika , the Bahamian-flagged MV ; Prestige , the Marshallese-flagged Deepwater Horizon , and the Liberian-flagged SS ; Torrey Canyon , MV Amoco Cadiz and MV Sea Empress ), the most common environmental criticism they face regards illegal fishing . These critics of the flag of convenience system argue that many of
8112-466: The invasion as a strategically defensive measure to blunt the edge of Iranian politician Ruhollah Khomeini , who had risen to power as Iran's " Supreme Leader " and was attempting to export the Islamic Revolution to the Arab world . Saddam, as a secularist and an Arab nationalist , perceived Iran's Shia Islamism as an immediate and existential threat to his Ba'ath Party and thereby to Iraqi society as
8216-467: The latter stages of the Tanker War. In 1987 the use of towed, radar-deflecting decoys and other passive countermeasures was successfully initiated. In total, well over 100 sailors were killed and a similar number wounded. More than 30 million tons of cargo was damaged from 1981 through 1987. It is in this conflict that in 1987 Iran perfected the art of speedboat attacks, and concentrated "their fire on
8320-518: The legal owners of their ships, making it difficult, if not impossible, to track who is the beneficial owner of the ship. The 2004 Report of the UN Secretary General's Consultative Group on Flag State Implementation reported that "It is very easy, and comparatively inexpensive, to establish a complex web of corporate entities to provide very effective cover to the identities of beneficial owners who do not want to be known." According to
8424-425: The marsh areas around the city, forcing the Iraqis to traverse through narrow strips of land. Iraqi tanks launched attacks with no infantry support, and many tanks were lost to Iranian anti-tank teams. However, by 30 September, the Iraqis had managed to clear the Iranians from the outskirts of the city. The next day, the Iraqis launched infantry and armoured attacks into the city. After heavy house-to-house fighting ,
8528-613: The middle of a voyage shortly before being seized by Australian authorities for smuggling heroin into that country. That year, thirteen nations began monitoring vessels under the North Korean flag for "illicit cargos like drugs, missiles or nuclear weapon fuel". In the accompanying material of the ILO's Maritime Labour Convention of 2006 , the International Labour Organization estimated that at that time there were approximately 1,200,000 working seafarers across
8632-414: The owner civilly or criminally responsible for a ship's actions. As a result of this lack of flag state control, flags of convenience are criticized on grounds of enabling tax avoidance, providing an environment for conducting criminal activities, supporting terrorism, providing poor working conditions for seafarers, and having an adverse effect on the environment. David Cockroft, former general secretary of
8736-426: The planned invasion. Iraq's 7th Mechanised and 4th Infantry Divisions attacked the Iranian border posts leading to the cities of Fakkeh and Bostan , opening the route for future armoured thrusts into Iran. Weakened by internal chaos, Iran was unable to repel the attacks; which in turn led to Iraq becoming more confident in its military edge over Iran and prompting them to believe in a quick victory. Iraq launched
8840-495: The practice of imprisoning sailors for the offense of desertion. Another aspect of the Seamen's Act was enforcement of safety standards, with requirements on lifeboats, the number of qualified able seamen on board, and that officers and seamen be able to speak the same language. These laws put U.S.-flagged vessels at an economic disadvantage against countries lacking such safeguards, and ships started to be re-registered in Panama's open registry from 1919. In addition to sidestepping
8944-416: The rate of its attacks and expanded their geographic scope by attacking ships serving more southerly Iranian points, particularly the oil-loading complex at Kharg Island . Two months later, Iran initiated its own attacks, and the tanker war became a two-way affair." Iraq broadened the tanker war in 1984 by attacking the oil terminal and oil tankers at Kharg Island . Iraq's aim in attacking Iranian shipping
9048-442: The regulations of the owners' country, which may, for example, have stricter safety standards. They may also select a jurisdiction to reduce operating costs, avoiding higher taxes in the owners' country and bypassing laws that protect the wages and working conditions of mariners . The term "flag of convenience" has been used since the 1950s. A registry which does not have a nationality or residency requirement for ship registration
9152-505: The riots had been inspired by the Iranian Revolution and instigated by Iran's government. On 10 March 1980, when Iraq declared Iran's ambassador persona non-grata , and demanded his withdrawal from Iraq by 15 March, Iran replied by downgrading its diplomatic ties to the charge d'affaires level, and demanded that Iraq withdraw their ambassador from Iran. In April 1980, in response to the Ba'ath Party declaring membership in
9256-492: The same year. Last two registries are still (2024) considered as FOC-s. As of 2024 , more than half of the world's merchant ships in terms of deadweight tonnage are registered in open registries or FOC-s. Open registries have been criticised, mainly by trade union organisations based in developed countries, especially those in the European Union, United States, Japan, Canada, or the United Kingdom. One criticism
9360-744: The ship is known as its registry. Registries may be governmental or private agencies. The reasons for choosing an open register are varied and include tax avoidance , the ability to avoid national labor and environmental regulations, and the ability to hire crews from lower-wage countries. National or closed registries typically require a ship be owned and constructed by national interests, and at least partially crewed by its citizens. Conversely, open registries frequently offer on-line registration with few questions asked. The use of flags of convenience lowers registration and maintenance costs, which in turn reduces overall transportation costs. The accumulated advantages can be significant, for example in 1999, 28 of
9464-404: The shipping industry the flexibility to recruit its manpower from alternate sources, with the result that developing and newly industrialized countries now provide the majority of seafarers for the entire global fleet – not just for the ships flying their own country's flag." International law requires that every merchant ship be registered in a country. The country in which a ship is registered
9568-619: The ships. To come into force, the 1986 treaty requires 40 signatories whose combined tonnage exceeds 25% of the world total. As of 2017 , only 14 countries have signed the treaty. Merchant ships have used false flags as a tactic to evade enemy warships since antiquity, and examples can be found from as early as the Roman era through to the Middle Ages . Following the American Revolutionary War , merchantmen flying
9672-408: The southern portion of the country. When Iraq laid siege to Abadan and dug its troops in around the city, it was unable to blockade the port, which allowed Iran to resupply Abadan by sea. Iraq's strategic reserves had been depleted, and by now it lacked the power to go on any major offensives until nearly the end of the war. On 7 December, Hussein announced that Iraq was going on the defensive. By
9776-447: The territory bounded by the cities of Khorramshahr , Ahvaz , Susangerd , and Musian . Iraqi hopes of an uprising by the ethnic Arabs of Khuzestan failed to materialise, as most of the ethnic Arabs remained loyal to Iran. The Iraqi troops advancing into Iran in 1980 were described by Patrick Brogan as "badly led and lacking in offensive spirit". The first known chemical weapons attack by Iraq on Iran probably took place during
9880-555: The two nations to increase further. Iraq also helped to instigate riots among Iranian Arabs in Khuzestan province, supporting them in their labor disputes, and turning uprisings into armed battles between Iran's Revolutionary Guards and militants, killing over 100 on both sides. At times, Iraq also supported armed rebellion by the Kurdish Democratic Party of Iran in Kurdistan. The most notable of such events
9984-443: The world. This document goes on to say that when working aboard ships flagged to states that do not "exercise effective jurisdiction and control" over their ships that "seafarers often have to work under unacceptable conditions, to the detriment of their well-being, health and safety and the safety of the ships on which they work." The International Transport Workers' Federation goes further, stating that flags of convenience "provide
10088-401: Was finally captured, the battle had delayed the Iraqis enough to allow the large-scale deployment of the Iranian military. In November, Saddam ordered his forces to advance towards Dezful and Ahvaz, and lay siege to both cities. However, the Iraqi offensive had been badly damaged by Iranian militias and air power. Iran's air force had destroyed Iraq's army supply depots and fuel supplies, and
10192-486: Was located near the border's southern end, to cut off the Shatt al-Arab from the rest of Iran and to establish a territorial security zone. The other two divisions invaded across the northern and central part of the border to prevent an Iranian counter-attack. On the northern front, the Iraqis attempted to establish a strong defensive position opposite Sulaymaniyah to protect the Iraqi Kirkuk oil complex . On
10296-483: Was one of the few legal sources of income for Taylor's regime. Liberia's registry is operated from Virginia, United States. To counteract class hopping , in 2009 the International Association of Classification Societies (IACS) established a Transfer of Class Agreement (TOCA). As of August 2024 , the open registries of Panama, Liberia, and Marshall Islands accounted for more than 46% of
10400-408: Was strangling the country through an aerial siege. On the other hand, Iran's supplies had not been exhausted, despite sanctions, and the military often cannibalised spare parts from other equipment and began searching for parts on the black market. On 28 November, Iran launched Operation Morvarid (Pearl), a combined air and sea attack that destroyed 80% of Iraq's navy and all of its radar sites in
10504-617: Was the Iranian Embassy siege in London, in which six armed Khuzestani Arab insurgents took the Iranian Embassy's staff as hostages, resulting in an armed siege that was finally ended by Britain's Special Air Service . A 2014 academic source confirms that the embassy attackers were "recruited and trained" by the Iraqi government. According to former Iraqi general Ra'ad al-Hamdani , the Iraqis believed that in addition to
10608-518: Was the first foreign ship to be re-registered in the Panamanian registry, and was employed in running illegal alcohol between Canada and the United States during Prohibition . The modern practice of registering ships in foreign countries to gain economic advantage originated in the United States in the era of World War I , though the term "flag of convenience" did not come into use until the 1950s. Between 1915 and 1922, several laws were passed in
10712-492: Was to provoke the Iranians to retaliate with extreme measures, such as closing the Strait of Hormuz to all maritime traffic, thereby bringing about foreign intervention against Iran; the United States had threatened several times to intervene if the Strait of Hormuz were closed. Kuwait and Saudi Arabia supported Iraq against Iran . The United States intervened in the conflict in 1986 to protect Kuwaiti tankers, and engaged in
10816-474: Was unnecessary. Iran's exclusion zone allowed for ships to enter and exit the Gulf, and essentially only kept such foreign ships out of its own waters. Iran's exclusion zone made it easier for Iraq to target Iranian ships. It allowed Iraq to assume that any ship in Iran's territorial waters must be going to (or coming from) an Iranian port. Phillips writes that "In January 1987, the Kuwaiti government proposed
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