On 12 March, Pole Star published an article saying that Deputy Assistant Secretary of State for Counter Threat Finance and Sanctions, had outlined details relating to a forthcoming advisory that will see the US State Department and OFAC now focusing on all areas of maritime trade and shipping.  It is said that the scrutiny included flag registries, ship owners and operators, ships (in particular ship types carrying specific cargoes under strategic sanctions programmes), chartering, insurance, ports, shipping service providers and the maritime supply chain as a whole.  It was emphasised that –

  • no organisation is too large or too safe to elude sanctions;
  • OFAC is focusing on sanctions that have an impact beyond the designated target itself;
  • knowledge of where a vessel has been operating including ports, regions, and jurisdictions is necessary;
  • the screening process must investigate all associated companies commercially and operationally engaged with the ship, including the ship’s beneficial ownership, registered owner, operator, and managers, its flag registry, and the associated companies’ country of registration, domicile, and control;
  • any suspicion of the use or presence of false documents must be reported to the appropriate authorities; and
  • one must be vigilant about, and investigate any suspicions of, ship-to-ship transfers.


If you’d like to help me buy that (badly needed) new laptop or, even better, a new desktop to replace the one now 5,000 miles away –

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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