OFAC Issues Guidance on Shipping and Sanctions Evasion

On May 14, 2020 The U.S. Departments of State and Treasury, and the U.S. Coast Guard, issued a global advisory​ to alert the maritime industry, and those active in the energy and metals sectors, to deceptive shipping practices used to evade sanctions, with a focus on Iran, North Korea, and Syria.  The advisory includes a detailed set of best practices for private industry to consider adopting to mitigate exposure to sanctions risk.

The Advisory covers:

  • Deceptive Shipping Practices
    1. Disabling or Manipulating the Automatic Identification System (AIS) on Vessels
    2. Physically Altering Vessel Identification
    3. Falsifying Cargo and Vessel Documents
    4. Ship-to-Ship (STS) Transfers
    5. Voyage Irregularities
    6. False Flags and Flag Hopping
    7. Complex Ownership or Management

 

  • General Practices for Effective Identification of Sanctions Evasion
    1. Institutionalize Sanctions Compliance Programs
    2. Establish AIS Best Practices and Contractual Requirements
    3. Monitor Ships Throughout the Entire Transaction Lifecycle
    4. Know Your Customer and Counterparty
    5. Exercise Supply Chain Due Diligence
    6. Contractual Language
    7. Industry Information Sharing
  • Guidance and information for:
      • maritime insurance companies
      • flag registry managers
      • port state control authorities
      • shipping industry associations
      • regional and global commodity trading, supplier, and brokering companies
      • financial institutions
      • ship owners, operators, and charterers
      • classification societies
      • vessel captains
      • crewing companies

    Information on North Korea-, Iran-, and Syria-related Sanctions Relevant to the Maritime Industry