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Pole Star Global: Combatting a new era of maritime sanctions evasion

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Deceptive shipping practices (DSPs), notably AIS spoofing and dark fleet activity, have surged in recent years. This presents a formidable challenge for sanctions compliance. Pole Star Global and Blackstone Compliance highlight this shift, emphasizing the critical need to comprehend, detect, and counter these practices. 

The imposition of Russia-related sanctions and price caps on Russian oil has triggered more sophisticated sanctions evasion methods. Threat actors aim to subvert authorities and financial compliance programs by establishing a shadow economy, evading US, UK, EU, and G-7 laws.

Sanctions evasion in the maritime sector is a complex issue. Covered persons involved in allied countries' markets face compliance obligations, especially regarding Russian oil's price cap. Yet, this cap leaves minimal margin, enticing threat actors to falsify documentation or attempt violations outside the cap, such as acting on behalf of blocked parties.

Warning signals from authorities have urged vigilance, particularly after OFAC singled out various entities to watch for DSPs as evidence of sanctions evasion. The UK’s National Crime Agency has also alerted the financial community to potential proxies and enablers used by sanctions targets, relevant to the maritime industry.

The emergence of illicit dark fleets and AIS spoofing poses significant challenges. The dark fleet comprises tankers outside allied jurisdictions, possibly engaging in sanctioned trade. However, not all vessels present the same risk, necessitating caution and enhanced due diligence for covered persons dealing with dark fleet vessels.

Determining a vessel's affiliation with the dark fleet involves scrutinizing ownership, movements, deceptive practices like AIS spoofing, timing of ownership changes, and fleet coordination, calling for a nuanced approach.


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AIS spoofing, once minor, has escalated significantly, especially for vessels carrying high-value cargoes. Threat actors now manipulate AIS data, presenting a complex challenge to maritime communities. False AIS data insertion occurs through various means, requiring continuous adaptation of countermeasures by maritime intelligence firms.

Spoofing techniques—anchor, circle, slow roll, and pre-programmed route—bear distinctive characteristics, demanding vigilant detection and analysis to differentiate valid and invalid transponders.

In conclusion, the threat of maritime sanctions evasion has intensified, demanding enhanced due diligence by covered persons. Working closely with maritime intelligence service providers becomes paramount to navigate this evolving landscape and counter DSPs effectively.


Source: Safety4Sea