Vessel identity laundering operations jeopardize the integrity of the IMO ship registration system, which the world relies upon in order to identify, track, and interact with the 60,000 ships, finds a new report.
ccording to C4ADS, vessel identity laundering is a novel tactic in which one or more vessels adopt a different identity on Automatic Identification System (AIS) transmissions in order to allow “dirty” ships to assume “clean” identities, and involves at least one vessel in this operation assuming an identity that is obtained by defrauding the IMO.
Vessel identity laundering is significantly more sophisticated than previously observed instances of “vessel identity tampering,” in which vessels modify their physical appearance or broadcast false data on AIS transmissions. Given its complexity, vessel identity laundering presents unprecedented challenges for maritime regulators and risks undermining global shipping practices
In recent years, C4ADS has observed at least 11 ships engaging in elaborate schemes to create fraudulent ship registrations with the IMO, which are subsequently used to “launder” the identity of vessels that have been associated with illicit activities. In particular, we have seen networks involved in DPRK sanctions evasion and smuggling use these tactics to avoid the heightened scrutiny of the sanctions regime.
This issue brief seeks to empower law enforcement and civil regulators to detect and disrupt vessel identity laundering operations by explaining how vessel identity laundering operations work and demonstrating how they can be detected using AIS data, satellite imagery, IMO registration records, and other sources of publicly available information.
The report covers two previously unreported case studies of vessel identity laundering involving DPRK fuel smuggling networks:
- The KINGSWAY, sanctioned by the UN Security Council (UNSC) for engaging in a ship-to-ship transfer with a North Korean tanker, laundered its identity into the APEX/SHUN FA in late 2018.
- The SUBBLIC, recommended for designation by the UN Panel of Experts for numerous deliveries of fuel to North Korea, laundered its identity into the HAI ZHOU 168 in mid-2019.
In light of this report’s findings, the authors suggest the following recommendations for the maritime community and its regulators.
- The IMO should require resubmission of vessel photographs and current details from operators at regular intervals for ships to maintain their registration, and deregister noncompliant vessels.
- The IMO should publish a list of IMO numbers that are cancelled and vessels whose registrations are rescinded.
- The IMO’s Maritime Safety Committee should coordinate a working group of representatives from government, industry, and civil society organizations to strengthen risk screening procedures for the IMO number application process.
- The IMO’s Maritime Safety Committee should promote transparency of the IMO number system by publishing annual reports that outline the measures taken to combat IMO number fraud, statistics on registration trends, case studies, and other guidance on evasion typologies.
- The IMO’s Maritime Safety Committee should coordinate a working group of representatives from government, industry, and civil society organizations to develop hardware and software security standards for preventing the tampering of AIS transponders. This working group should produce a list of AIS transponder models that meet anti-tampering standards for both Class A and Class B transponders. The transponder model’s certification should be reviewed regularly.
- Flag registries and other maritime authorities should implement tools and methods to detect AIS tampering or anomalies by ships under their jurisdiction, and information on detected cases should be published and shared with other maritime regulators.
All maritime regulators and enforcement agencies should detain and investigate ships that have painted over their original IMO number and marked a different one, as well as any other entities responsible for facilitating identity tampering.
The IMO should mandate the expansion of ship information provided in GISIS to include the following data points:
- Vessel specifications (e.g. length, breadth, gross tonnage, deadweight tonnage);
- Historical MMSI numbers and call signs, complete with periods of use;
- Photographs submitted to the IMO.
- The IMO should mandate the GISIS to distinguish whether a vessel’s flag registration is provisional or permanent. If a vessel’s flag registration is provisional, GISIS should indicate the date of issue and expiry. GISIS should prominently mark the vessels whose provisional flag registration status has expired.
- The IMO should create a secure communication channel where the public and whistleblowers can submit information on vessels, individuals, companies, and officials that are abusing or facilitating the abuse of the IMO number system.
- The UN Panel of Experts on the DPRK should include in its midterm and final reports a table of fraudulent IMO-registered and AIS identities used by vessels linked to DPRK sanctions evasion activities.
- Governments should regularly publish circulars and advisories that include lists of fraudulent IMO-registered and AIS identities used by DPRK-linked vessels. Governments should ensure that these blacklists are disseminated to authorities responsible for maritime security.