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
- Disabling or Manipulating the Automatic Identification System (AIS) on Vessels
- Physically Altering Vessel Identification
- Falsifying Cargo and Vessel Documents
- Ship-to-Ship (STS) Transfers
- Voyage Irregularities
- False Flags and Flag Hopping
- Complex Ownership or Management
- General Practices for Effective Identification of Sanctions Evasion
- Institutionalize Sanctions Compliance Programs
- Establish AIS Best Practices and Contractual Requirements
- Monitor Ships Throughout the Entire Transaction Lifecycle
- Know Your Customer and Counterparty
- Exercise Supply Chain Due Diligence
- Contractual Language
- Industry Information Sharing
- Guidance and information for:
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- 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
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