In a recent blog post, OFSI issues ‘refreshed’ guidance on the effect of financial sanctions in the maritime sector, including “new tactics used by illicit actors to evade UK financial sanctions”, emphasising the need for entities from a broad range of sectors – including financial services – to consider the same.
The guidance itself highlights a number of evasion tactics, including:
a. ‘false flag operations’, where a vessel seeks to deceive by misrepresenting the flag under which it operates;
b. ‘ship to ship transfers, involving the transfer of cargo from one vessel to another while at sea; and
c. the use of false or fraudulent documentation.
OFSI’s blog post indicates a renewed focus on sanctions in the maritime sector, which will include a “series of guidance and engagement to support those in the maritime sector”.