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 have issued a global advisory alerting the maritime industry, and those actively engaged in the energy and metals sectors, to deceptive shipping practices used to evade sanctions throughout the world, and specifically in Iran, North Korea and Syria. The new advisory is intended to provide specific guidance and recommended best practices to be used by those in the maritime industry to ensure sanctions compliance. The advisory highlights the most common practices used by sanctions evaders, including (1) disabling or manipulating the AIS on the vessel; (2) physically altering vessel identification; (3) falsifying cargo and vessel documents; (4) STS transfers; (5) voyage irregulates; (6) false flags and flag hopping; and (7) complex ownership or management structures.
The advisory also includes a detailed set of general practices which should be adopted for various sectors of the industry to assist in identifying potential sanctions evaders. An internal compliance program and strict “know your customer” guidelines should be developed and implemented with these guidelines in mind in order to ensure compliance with U.S. sanctions regulations.
To read a copy of the advisory please click here.
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