The tactics employed in subterfuge shipping activities are continuously evolving to try and stay ahead. Although many of the tactics utilised have been previously described by regulators, they have since transformed or been taken to new extremes. We will discuss some of these evolutions to provide better transparency into what is and continues to be a convoluted landscape.
On May 14, 2020, the US Treasury's Office of Foreign Asset Control (OFAC) released what would become a foundational advisory, identifying and recommending controls to combat some of the key principles of subterfuge shipping. The seven elements that were highlighted are now integral in many compliance frameworks. The focus at the time concerned Iran, North Korea and Syria, but many of these practices now apply toward activities taking place in Venezuela and Russia. The seven tactics highlighted are outlined below.
On Oct. 12, 2023, OFAC released a secondary advisory, relating to that of the price cap coalition for the maritime oil industry and related sectors. This held seven recommendations as outlined below.
Disabling and manipulating AIS
Most of the observed evolution that has taken place within the realm of deceptive shipping can be attributed to that of disabling or manipulating the AIS on board vessels. This section is broken into two parts. The first will discuss elements relating to that of the identity of a vessel; this is fundamental in understanding how certain practices relating to disabling/manipulating AIS. The second part will focus on AIS, what it is, some of the limitations and practices relating to it, including that of deceptive shipping.
Vessel identifiers
Although on a day-by-day basis we might refer to vessels using various "identifiers," such as an IMO number, an MMSI and others, it is important to note that elements relating to identity can be classified in three different categories — "registered identity", "physical identity" and "digital identity". All these facets are important as individual concepts, but also collectively to correctly identify a vessel. READ MORE