The Office of Foreign Assets Control (OFAC) is responsible for administering and enforcing economic sanctions against targeted foreign countries, geographic regions, entities, and individuals to further U.S. foreign policy and national security goals. All U.S. persons must comply with OFAC sanctions. OFAC strongly encourages organizations subject to U.S. jurisdiction, as well as foreign entities that conduct business in or with the United States, U.S. persons, or using U.S.-origin goods or services, to employ a risk-based approach to sanctions compliance.
Maritime sector stakeholders, including commodities brokers, insurers, ship management service providers, shipbroking companies, and port authorities, are often at the forefront of the sanctions compliance landscape as malign actors in the industry employ increasingly sophisticated deceptive practices to evade sanctions. To address risks such as the manipulation of vessel location data, document falsification, and vessel ownership obfuscation, many industry stakeholders have implemented sanctions compliance practices such as conducting additional due diligence on vessel ownership and using enhanced tracking systems for vessels and cargo.
OFAC is publishing this scenario-based guidance to aid maritime sector stakeholders in identifying certain new or common fact patterns that may be indicative of sanctions evasion, addressing common counterparty due diligence issues, and implementing best practices to promote sanctions compliance.
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