The complexity of the maritime sanctions landscape is not one to underestimate. Careful consideration needs to be taken by the industry. With the trading world merchant fleet projected to reach 79,282 vessels by the end of 2025, it is critical that the industry remains compliant with sanctions, along with an awareness of deceptive tactics used to evade sanctions.
1. Complex ownership structures
The Swedish Group regards complex ownership structures as a common tactic of malign actors. This method sees complex structures, including shell companies, varying levels of ownership and management, as well as intertwined employees between organisations. The full report discusses an in-depth investigation that uncovered Winson Shipping’s multiple levels of involvement in unlawful activities that saw North Korean sanctions programs severely violated.
2. AIS outages
Switching off the automatic identification system (AIS) or “going dark”, and altering the outputs or transmitted information is a method which has been used to hide vessel locations.
3. Ship-to-ship transfers
This method involves moving cargo at sea as opposed to in a port. The moving of cargo in this way allows for the origin, destination and even type of cargo to be concealed, or at least attempted to be.
You can find out more about the public consultation on the United Kingdom’s future legal framework for imposing and implementing sanctions in the Government’s whitepaper.
4. Vessel identity laundering
Whether through transmitting incorrect AIS information or altering the vessel’s physical state to vessel registration changes this is a tactic used to attempt to conceal a vessel’s identity.
5. Falsifying documents
Altering documentation is another attempt used to obscure a vessel’s intentions, goods, destination and, at times, origin.
These five deceptive practices are used in attempts to evade sanctions. Flag hopping, routing inconsistencies, loitering in high-risk areas and physical alterations to vessels are all strategies also used as evasion methods.
Want to learn more about maritime sanctions compliance?
Further details of the areas discussed within this article can be found within our latest report ‘Maritime Compliance – The rapidly changing maritime sanctions compliance landscape’. This guide to industry includes discussion on the landscape as well as sanctions compliance measures and how best to mitigate against the many associated risks.
