On 13 September, Windward reported that it and law firm Ince had jointly consider the new phenomenon of Russian grain laundering and the legal exposure for the maritime industry. Windward had found that ship-to-ship (STS) transfers were being used to steal, and subsequently smuggle, Ukrainian grain, and this had prompted much discussion around the possible legal exposure and how concerned the market should be.
https://windward.ai/blog/maritime-legal-exposure-in-a-post-grain-laundering-landscape
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