May, 2020 - US guidance regarding illicit shipping and sanctions evasion practices

US authorities issue guidance to maritime industry regarding illicit shipping and sanctions evasion practices

On 14th May, 2020, OFAC, the US Department of State, and the US Coast Guard published a Sanctions Advisory for the Maritime Industry, Energy and Metals Sectors and Related Communities. The Advisory, which can be accessed here, provides guidance to those in the maritime industry and energy and metals sectors, regarding illicit shipping and sanctions evasion. 

The Advisory focuses on Iran, Syria and North Korea. It identifies seven recent trends in deceptive shipping practices related to those countries, and suggests methods to enhance sanctions compliance procedures and policies to manage the risks associated with the trends identified. 

The Advisory suggests specific measures to be adopted by many players in the maritime industry, including ship owners, operators and charterers, ship captains, crewing companies and commodity trading, supplier and brokering companies.

Whilst the Advisory is not binding, it is indicative of the measures that the US authorities will consider to be acceptable sanctions risk controls for anyone in the maritime, energy or metals sector. As such, Members should consider whether any of the recommendations contained within the Advisory can be incorporated into their own sanctions policies and procedures, where appropriate.

More information can be found in the following article published by Freehill, Hogan & Mahar LLP