On 18 October, Hellenic Shipping News reported that vessels involved in STS transfers thus risk unwittingly facilitating unlawful exports and legal repercussions such as seizure of assets and exclusion from the US financial system. This article highlights the primary legal risks of such practices and suggests key steps for members to avoid unwanted repercussions.  It starts by saying that STS transfers are the transfers of crude oil, petroleum products, liquid bulk chemicals and liquefied gas between tankers while at sea, without the vessel having to call at a port or other facility.  Many STS transfers are legitimate; however, suspicious circumstances such as operations at night and in high-risk areas, anchoring or drifting near sanctioned countries, and missing AIS data should raise immediate concern.

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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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