On 5th June, Project Alpha published a report on the March 2019 session.  The Legal Committee of the International Maritime Organisation (IMO) agreed that the IMO would work with the UN Security Council to create a searchable database that would show vessels subject to UN resolutions, saying that it is concrete evidence of the IMO beginning to address the issue of sanctions compliance. The report notes 4 areas where the IMO has a uniquely useful part to play in other aspects of sanctions enforcement as well –

  • Obtaining and sharing information on group beneficial owners;
  • Guidance on best practice for running a shipping registry;
  • Conducting its own sanctions checks; and
  • Information-sharing on de-registrations by flag states.

The report concludes that information requirements in maritime sanctions implementation go well beyond the measures proposed at the meeting.  Risk management in both the public and the private sector is arguably more concerned with high-risk non-designated entities than the proposed more easily searchable list of designated entities.  Direct or indirect connections to any sanctions-related infringements, such as port denials, seizures, or involvement in ship-to-ship transfers, are relevant.  Whilst it is impractical to lay all this at the door of the IMO, its increased engagement with sanctions implementation will be welcomed by the public and private sector alike.

Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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