Treasury's Office of Foreign Assets Control (OFAC), in coordination with the State Department and the US Coast Guard, has issued a Guidance to Address Illicit Shipping and Sanctions Evasion Practices, which is a guide to deceptive shipping practices, employing what we call sanctions evasion tradecraft. The report focuses on Iran, North Korea and Syria.
The topics include:
(A) DECEPTIVE SHIPPING PRACTICES
(B) DISABLING OR MANIPULATING THE AUTOMATIC IDENTIFICATION SYSTEM ON VESSELS.
(C) PHYSICALLY ALTERING VESSEL IDENTIFICATION
(D) SHIP-TO-SHIP TRANSFERS
(E) VOYAGE IRREGULARITIES
(F) FALSE FLAGS AND FLAG HOPPING
(G)COMPLEX OWNERSHIP OR MANAGEMENT
(H)GENERAL PRACTICES FOR EFFECTIVE IDENTIFICATION OF SANCTIONS EVASION
(I) INSTITUTIONALIZE SANCTIONS EVASION COMPLIANCE PROGRAMS
(J) ESTABLISH AIS BEST PRACTICE AND COMPLIANCE REQUIREMENTS
(K) MONITOR SHIPS THROUGHOUT THE ENTIRE TRANSACTION LIFECYCLE
(L) EXERCISE SUPPLY CHAIN DUE DILIGENCE
(M)ADDITIONAL RESOURCES
You can access the 35-page report here.
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