Sanctions Experts Highlight New ‘Dark Fleet’ Advisories
Sanctions compliance professionals should familiarize themselves with several advisories authorities recently issued to help spot “dark fleet” vessels that seek to evade the price cap on Russian oil sales or oil sanctions on Iran and Venezuela, experts said April 4 during a webinar hosted by the Association of Certified Sanctions Specialists.
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The “know your cargo” advisory from five agencies, including the Treasury Department and DOJ, said the maritime industry should understand the buyer, vessel and vessel’s charterer and verify the cargo’s origin and destination (see 2312110060).
The coalition price cap advisory calls for the maritime and financial services industries to conduct due diligence on vessels engaged in oil-related transactions (see 2310120029). These steps can include monitoring a vessel’s voyage with Inmarsat-C data, identifying ship-to-ship transfers and ensuring the vessel is appropriately classed and insured.
The Office of Foreign Assets Control’s alert on spoofing, or faking a ship’s location, tells financial institutions and maritime providers to use maritime intelligence organizations to identify such activity (see 2304170033).
Complicating matters is a recent advisory from the U.S. Maritime Administration that recommends Western vessels turn off their automatic identification system (AIS) transponders in certain dangerous parts of the globe, said Marc Armas, a lawyer with Walden Macht. Turning off an AIS has traditionally been considered a red flag for potential sanctions evasion.
"That's just something you need to be able to keep in mind and understand as part of the fuller picture of the maritime-related advisories and some of the real-time effects that are happening simultaneously," Armas said.
The "dark fleet" consists of about 1,000 oil tankers that seek to evade the Russian price cap or Iranian or Venezuelan sanctions, said David Tannenbaum, director of Blackstone Compliance Services. Spoofing and ship-to-ship transfers are the most common deception practices.
Ship-to-ship transfers are not necessarily illegal but are often used to obfuscate the origin of cargo. With both ship-to-ship transfers and turning off an AIS, "it requires context," Tannenbaum said.