Global Maritime Advisory aims to create compliance standards across industry

Two ships engage in a ship-to-ship (STS) bunker transfer—the transfer of cargo between ships at sea. While STS transfers can be conducted for legitimate purposes, these transfers—especially at night or in areas determined to be high-risk for sanctions evasion or other illicit activity—are frequently used to evade sanctions. (Note: this photo is not an example of a specific sanctions evasion instance). Photo by Erkut-Acar
Two ships engage in a ship-to-ship (STS) bunker transfer—the transfer of cargo between ships at sea. While STS transfers can be conducted for legitimate purposes, these transfers—especially at night or in areas determined to be high-risk for sanctions evasion or other illicit activity—are frequently used to evade sanctions. (Note: this photo is not an example of a specific sanctions evasion instance). Photo by Erkut-Acar

By Kacie E. Yearout

Following several months of drafting, incorporating private sector feedback and interagency contributions, the Department of State published the Global Maritime Advisory in May, which addressed the illicit shipping practices Iran, Syria, and North Korea employ to evade sanctions.  

While invisible to most Americans, the shipping industry influences economic markets and supply chains worldwide. More than 200 countries have ports open to container and cargo ships, which move 90 percent of the world’s trade. The magnitude of the industry makes it ripe for sanctions evaders seeking to exploit loopholes. 

“Maritime shipping and its related industries remain key mechanisms for enabling the proliferation of [weapons of mass destruction], their delivery systems, and conventional arms transfers of concern, as well as an important source of revenue and influence for proliferator states,” said Thomas Zarzecki, acting director of the Bureau of International Security and Nonproliferation’s Office of Counterproliferation Initiatives.  

The Department’s Bureau of Economic and Business Affairs (EB) and Bureau of International Security and Nonproliferation (ISN) had detected similar behavior patterns across regions that often indicated sanctions evasion. The Department engaged in dialogues with private industry on how best to establish information sharing and common compliance standards.

In late 2019, EB and ISN put pen to paper to draft a Global Maritime Advisory that could be used across the maritime sector, including ship owners, registries, port states, captains, and others. 

“Economic security and national security are linked. Risk-based compliance is important more than ever. The private sector needs to know everyone involved in a transaction to ensure recipients and counterparties are not sending or receiving commodities that may trigger sanctions,” said Blake Pritchett, EB’s deputy director for Sanctions Policy and Implementation. 

The advisory was published with the U.S. Coast Guard and Department of the Treasury and provided a review of deceptive practices and sector-specific measures to elevate compliance across the industry.

Since its publication, EB and ISN have participated in private-sector engagements promoting the advisory. The advisory will play a role in engagements over the next several years. 

Kacie E. Yearout is a foreign affairs officer in the Bureau of Economic and Business Affairs’ Office of Economic Sanctions Policy and Implementation. 

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