The Department for Transport (DfT) has written the latest blog entry on the Office of Financial Sanctions Implementation (OFSI) blog. This blog provides a brief background on transport sanctions, and insights on DfT's Transport Sanctions team and how they work with other government departments on sanctions enforcement.
The Transport Sanctions team was created to lead on areas of the Sanctions and Anti-Money Laundering Act (SAMLA) "which sit within DfT’s natural area of expertise". This includes enforcing restrictions on movement, registration, ownership and use of ships and aircraft. For example, DfT may work with air traffic control authorities to prohibit a plane from flying over the UK if necessary under sanctions restrictions, or to prevent sanctioned ships from entering UK ports.
As another example, DfT might detain a ship in a UK port if they have reasonable grounds to suspect the ship is carrying goods prohibited under sanctions legislation. It would then work with other agencies including OFSI, the Department for International Trade, and HMRC to investigate any a potential breach of financial sanctions or trade restrictions.
DfT underscores the complexity of identifying sanctions evasion through transport, including spotting signs such as falsified documents, obscured ownership or hiding a ship's registry or type of goods being shipped, stating that response requires good communication and a multifaceted approach. It concludes the post by saying that it "recognise[s] the crucial importance of talking to industry stakeholders to learn from experiences and expertise" and provides a dedicated sanctions enquiries email address.
From almost the first moment someone fashioned wood into a canoe to transport people and goods across a river there has been some form of maritime regulation. As with any regulations however, there will always be someone who seeks to circumvent them. Issues such as falsifying documents, obscuring ownership and hiding a ship’s registry have been endemic in the shipping industry for centuries.