The report outlines a number of questionable practices used to trade in sanctioned goods at sea, reinforcing the need to develop compliance frameworks for stakeholders across the wider maritime ecosystem.
In the first place, the report explains what are the financial sanctions and where they are generally imposed to.
According to the report
Financial sanctions help the UK meet its foreign policy and national security aims, as well as protecting the integrity of its financial system.
The financial sanctions specifically relate to restrictions on funds and economic resources that are owned, held, controlled or made available to, or for the benefit of, designated persons or entities.
It is noted that individuals and entities with exposure to the maritime shipping sector should be aware of the non-exhaustive list of illicit practices and ensure compliance and due diligence procedures take account of them.
Thus, the illicit practices include:
- Ship-to-ship transfers
- Automatic Identification Systems (AIS)
- Cyber activity
- Financial system abuse
- False documentation
Keep in mind that the practices described above are not necessarily in themselves breaches of financial sanctions regulations in all cases. However, it is likely that transactions relating to or behaviours underpinning these practices, are.
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