The dynamic nature of sanctions means there are frequent changes and updates ranging from newly sanctioned entities to or changes to embargoes and tariffs put in place. Accordingly, many new and evolving sanctions evasion attempts are ongoing. In our 5 ‘red flags’ article, we discussed a handful of the many tactics used to attempt to evade sanctions.
Due to the severity of the penalty that a violation can result in, companies must take proactive and protective measures to best protect themselves including a high level of awareness of evasion methods and tactics that are commonly deployed including:
The concealment of the identity of an owner is often a tactic used in attempts to deceive individuals.
The creation and use of false entities, whether an individual, company, charterer or even shipping registry are all areas that are exploited in the avoidance of sanctions. Fraudulent shipping registry activity, such as that reportedly experienced by Fiji and Samoa, as well as other countries, has seen governments, companies, and individuals unknowingly conduct business transactions with entities that are involved, or have ties and connections, with disqualified parties.
Performing cargo screening checks is critical is risky. In 2013 a North Korean-owned and flagged ship on passage from Cuba was discovered to be carrying an array of undeclared weapons of war.
Several physical attempts to mislead authorities and conceal these weapons were made.
However, when stopped by Panamanian customs officials and physically checked, the 20,000 loaded bags of sugar were found to be covering twenty-five shipping containers that held an arsenal of military-grade weapons and systems including; six surface-to-air missile systems, and ammunition manufacturing equipment as well as disassembled fighter jets.
The physical covering of the containers with sugar bags was one of many attempts made, with the creation of false stowage plans, falsified ship logs and the use of corrupt shipping agents all noted as
playing a role.
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.