In an article dated 31 December, Hellenic Shipping News reported that, in light of advisories issued by OFSI and OFAC, it would seem opportune to identify how big the actual burden is, where the pain-points exist, and how they could be managed.  It says that 4 advisories published by OFAC since February 2018 have all concentrated in detail on a few distinct areas as the basis for a sanctions screening program concerning vessels and their movements and owners.  OFAC and OFSI Advisories recommend compliance mechanisms that go well beyond the standard screening of owners, operators and vessels against sanctions lists.  The new compliance measures include historical and continued analysis of AIS transmission data, AIS-related contract clauses, careful scrutiny of shipping documents, and ‘know your vessel’ checks.  It lists expected risk indicators and red flags.  It also says that in last 3 months (July-October 2020), the number of tankers, bulkers, general cargo and container ships to have visited sanctioned ports were 2,281 vessel arrivals at Iranian ports; 60 vessels arrived at DPRK ports; and 1,353 arrivals to Venezuela.   It says that the extra workload on bank trade finance operations teams regarding maritime screening has come about due to expansion of international sanctions evasion tactics by shipping companies, corporates, and nation-states who are finding new ways of circumventing regulations.

If if you would like to make a (polite) gesture and make a (very) modest contribution to my ongoing with my relocation, removal and computer costs, I have a page at

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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