- OFAC warns global parties involved in petroleum shipments of U.S. sanctions risks and encourages robust due diligence.
- Key recommendations include strengthening AML/CFT compliance, monitoring for AIS manipulation, and thorough KYC due diligence.
- Red flags such as AIS data manipulation or inaccurate shipping documentation should be investigated before proceeding with transactions.
The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has issued a global advisory to alert parties involved in petroleum shipments of the significant U.S. sanctions risks. OFAC urges commercial entities to conduct sufficient due diligence to avoid sanctions violations, which can also lead to business and reputational risks, reports SAFETY4SEA.
Strengthen AML/CFT Compliance
OFAC advises companies to strengthen their anti-money laundering and countering the financing of terrorism (AML/CFT) compliance measures.
Companies should adopt policies and procedures in line with Financial Action Task Force standards, promote beneficial ownership transparency for legal entities, and ensure thorough due diligence in financial and non-financial transactions.
Monitor AIS Manipulation
Automatic Identification System (AIS) manipulation can be a red flag for illicit activity. While turning off AIS transponders may sometimes be legitimate (such as in piracy zones),
OFAC recommends that ship registries, insurers, vessel owners, and other stakeholders investigate ships that turn off AIS for extended periods, especially in the Mediterranean and Red Seas.
Investigate Manipulated Shipping Documentation
OFAC advises reviewing all shipping documentation carefully. Any discrepancies or manipulated data related to shipments involving petroleum, particularly those bound for Syria or involving Iranian oil, should raise red flags.
Parties should ensure the documentation is accurate and fully investigate any signs of manipulation before continuing with the transaction.
Conduct KYC Due Diligence
Know Your Customer (KYC) protocols are essential for those involved in the maritime petroleum shipping industry. Stakeholders are urged to research the history, ownership, and activities of the vessels, companies, and individuals involved in transactions.
Investigating a vessel’s IMO number can provide a detailed understanding of its history and potential sanctions risks.
Maintain Clear Communication with International Partners
OFAC emphasizes the importance of clear communication between parties involved in international transactions.
Different sanctions regimes may apply depending on jurisdictions, so clear discussions on applicable sanctions frameworks are essential for compliance.
Utilize Available Resources
OFAC encourages leveraging commercial shipping data, including ship location, registry information, and flagging details, to enhance due diligence.
Organizations provide useful data that can help ensure compliance, alongside the “Syria Sanctions Resources” provided by OFAC.
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Source: SAFETY4SEA