The U.S. Department of State, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC), and the U.S. Coast Guard has issued an advisory to those engaged or involved in trade in the maritime industry and energy and metals sectors on typologies used to facilitate illicit trade, particularly linked to Iran, North Korea, and Syria.
The lengthy report, which follows and expands on advisories issued in 2018 and 2019, contains specific guidance for various actors in the maritime sector including: maritime insurance companies; flag registry managers; port state control authorities; shipping industry associations; trading, supplier and brokering companies; financial institutions; ship owners, operators and charterers; classification societies; vessel captains; and crewing companies.
Some of the typologies include:
- disabling the Automatic Identification System (AIS) on vessels
- physically altering vessel identification
- falsifying cargo and vessel documents
- ship-to-ship transfers
- voyage irregularities
- false flags or "flag hopping"
- complex ownership or management structures.
Best practices for identifying these typologies include risk-based due diligence and monitoring on customers and supply chains, formal compliance programmes, and including contractual protections in documentation.
Approximately 90 percent of global trade involves maritime transportation. Malign actors constantly seek novel ways to exploit global supply chains for their benefit... We recommend that persons conducting any transportation or trade involving the maritime sector continue to be vigilant against the following tactics in order to limit the risk of involvement with sanctionable or illicit activity, and that they exercise heightened due diligence with respect to shipments that transit areas they determine to present high risk.
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