Vessel Screening refers to datasets and platforms which help companies identify vessels, companies, and individuals who’ve been engaged in both sanctions’ breeches and deceptive shipping practices.

What are the deceptive shipping practices?

Disabling or manipulating the AIS: In its simplest form, this manifests as the AIS transponder on the vessel being switched off, and the vessel ‘going dark’ necessitating the use of tools which can either continue to track without AIS (LRIT, Satellite Imagery or other satellite tracking capability), or the use of modelled outputs to predict what a vessel has done in this time.

Suppliers have developed algorithms to provide an indication on whether the vessel could have completed a ship-to-ship transfer or called into a port based on its characteristics and cargo.

These tools will also look at other vessels within the area to ascertain if there are signals which are still being picked up, which would indicate the AIS has indeed been switched off by the vessels in question.

On top of this, the OFAC Memorandum also refers to the prevention of ‘Spoofing’ which is the manipulation of an AIS signal to misrepresent the position of said vessel, without turning the AIS off. This is becoming a more common occurrence and there are newer tools designed to identify vessels whose behaviour is irregular or to corroborate the vessels reported position with other tracking to identify whether a vessel is where it’s AIS says it is.

Physically altering vessel identification: Physically painting a vessel a different colour showing a different name/flag/IMO number on the hull. Some organisations have responded to this by providing vessel imagery.

Falsifying cargo and vessel documents: Vessels/company’s looking to evade sanctions have falsified documents including Bills of Lading( BoL), or cargo origin documentation. OFAC make specific reference to petrochemicals, petroleum, petroleum products, or metals (steel, iron) or sand in order to disguise their origin. 

Ship-to-ship (STS) transfers: STS transfers at sea, especially at night or in high-risk areas for sanctions evasion or other illicit activity, are frequently used to evade sanctions by concealing the origin or destination of cargo.

As with Manipulating AIS this is an area in which organisations have developed both simple and sophisticated tools to monitor this behaviour.

Typically, STS occurs while at least one of the vessels is not broadcasting their AIS, but the most basic flag is to look for two vessels next to one another for a specific period of time (6/12/18/24 hours for example) and to report this.

If one or more vessels is not broadcasting their AIS position, the simple tools will look for vessels which have turned off their AIS in close proximity to one another (with some complexity built in by scanning the area around these vessels to see if other AIS signals can be picked up) and flag a potential STS.

The more complex solutions utilise algorithms to determine the likelihood of an STS, looking at previous behaviours, compatibility of the vessels involved, the time take and the respective draughts of the vessels, amongst other variables to provide some kind of risk score.

Voyage Irregularities: Bad actors attempt to disguise the ultimate destination or origin of cargo by using indirect routing, unscheduled detours, or transit or transhipment of cargo through third countries. Suppliers have developed algorithms to identify what ‘normal behaviour’ is, including look at vessels which don’t have port calls for a long time, deviations to regular trading routes and other variables.

False flags and flag hopping: Illicit actors falsified the flag of their vessels to mask illicit trade. They also repeatedly registered with new flag states to avoid detection, also known as “flag hopping”. The solution to this is slightly simpler, the suppliers will use characteristics and ownership data to look at frequent or sudden changes of Name/Flag/P&I Club/Class to ascertain risk and score appropriately. There are also published lists of flags which have different risk factors associated with them, as an extreme example if a vessel moves from a UK flag to an Iranian flag, that will massively impact the risk. 

Complex Ownership or Management: Sanctions evaders used shell companies and/or multiple levels of ownership and management, to disguise the ultimate beneficial owner of cargo or commodities. Suppliers will use either their own proprietary, or purchased, ownership databases to ascertain ownership and provide a risk score based on these structures.

Oil Price Cap and Russia Sanctions: The most recent sanctions packages have focused on targeting vessels which have conducted business with Russia over the value of $60 per barrel of oil. This involves the complex addition of attestations on pricing. In practice regulators are looking at vessels which went dark in proximity to Russian terminals or known STS locations, and tracking these activities will be vital in providing any regulator’s investigations with evidence of a robust internal policy.

Suppliers have used these different factors to create a Red, Amber, Green (RAG) scoring methodology to enable their customers to quickly identify and escalate vessels. Most of these providers also allow their customers to customise certain variables to match their own risk appetites. The methodologies of these risk scores provide different weightings based on the above variables, to build a ‘picture’ of the risk profile of a vessel/Vessels.

Alerting services for changes in risk profiles of vessels saved to watchlists are also a significant feature.

Benefits

As these are all regulatory requirements, it’s hugely beneficial to have a system in place which will help organisations search for all these practices at once.

Drawbacks

As a number of these tools utilise AI, machine learning, and other algorithmic approaches they can sometime create more questions than they answer.

False positives are a common occurrence, which can slow down or prevent perfectly legitimate business to from being conducted.