Navigating Sanctions Compliance in Marine Insurance

By Graham Libaert, Director of Alliances, Concirrus, IUMI Professional Partner,’s recently urged marine insurers to review their compliance procedures around international sanctions to limit their exposure to breaches. Marine insurers have an extremely tough job, caught in the middle of US Sanctions, EU law, divergent jurisdictions and daily changes to sanctions lists. Despite these challenges, technology can play a significant role in helping insurers limit their exposure.

Insurers can limit their exposure from the outset by completing their company and financial due diligence upfront. Several specialised services provide screening solutions that use pro-active monitoring for changes in company and ownership structure whilst the cover is in force. However, the idiosyncrasies of each technology mean that combined solutions may be required to achieve meaningful results.

Automatic Identification System (AIS) data allows insurers to track journeys and, if everything aligns, offers some inference regarding breaches of sanctions by analysing operating patterns. The transmission however can be lost as a result of the local environment. We looked at one example in Iran and ran the data against AIS and ICEYE’s SAR satellite technology. ICEYE detected 33 vessels of a commodity trading size in Iranian waters over two passes, in January 2019. AIS detected nine trading vessels in the same area. Further analysis by Concirrus revealed that five of the nine vessels reporting AIS were in fact spoofed and four were Iranian. Using multiple data sources helps bridge the gaps that currently exist as new technology becomes readily available.

Using behavioural analytics, insurers can benefit from alerts based on a variety of activity that could point to international sanctions breaches such as: zone entry, ship-to-ship transfer, signal loss and suspicious behaviour. Machine Learning (ML) algorithms can help identify these types of activity using multiple data sources, reacting to real-time changes in the data, providing an underwriter with the tools to interpret the risk in ways not previously possible. With greater visibility of activities and anomalies, insurers are in a better position to spot the early warning signs of potential illegal behaviour and act to limit their exposure.

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