Maritime Sanctions: Latest Developments
The US Treasury’s Office of Foreign Assets Control (OFAC) has issued a new maritime sanctions advisory that signals a significant shift in compliance expectations for the industry. The advisory, released on April 16, 2023, builds upon the deceptive shipping practices (DSPs) introduced in 2020 and expands the scope of what regulators consider red-flag behavior, particularly in connection with Iranian oil exports and shadow fleet activity.
The advisory emphasizes the importance of a “Know Your Vessel” (KYV) approach, which involves continuous, behavior-based vessel risk assessments that go beyond static lists. This approach is not new to Windward, as it has been a pioneer in KYV and has even trademarked the term. The company’s KYV framework operationalizes maritime due diligence by delivering dynamic, real-time risk assessments across behavior, ownership, cargo, and connections.
The advisory’s foundation lies in OFAC’s 2020 guidance, which recognized that sanctions evasion is not just about who is on the list but also how entities behave. This shift marked a turning point in maritime compliance, as regulators began to focus on detecting and responding to deceptive shipping practices such as AIS spoofing, flag hopping, complex ownership structures, and ship-to-ship (STS) transfers.
Fast-forward five years, and OFAC’s 2023 advisory has introduced new layers of scrutiny, including shadow fleets operating under obscure ownership and poor safety standards, falsified documentation and identity manipulation, location (GNSS) manipulation, zombie vessels, and a demand for proof for vessels claiming legitimate AIS disablement. Multiple STS transfers now warrant a full investigation, not just of the primary vessel but of every entity involved.
Mitigating this level of risk requires full behavioral visibility and the ability to connect the dots across vessels, fleets, and ownership networks. This is where KYV becomes essential, as it empowers stakeholders across trade, finance, energy, and government to vet vessels with confidence, using the full picture of ownership and behavioral risk.
Windward’s KYV framework includes dynamic vessel risk scores powered by proprietary AI models, ownership and flag history tracking, deceptive behavior detection, network analysis of affiliations with high-risk jurisdictions, and behavioral risk pattern. This comprehensive approach goes beyond static screenings to deliver real-time risk assessments that can help organizations protect themselves from operational and reputational risks associated with maritime trade.
In today’s enforcement landscape, reactive compliance is no longer enough. Vetting a vessel once or just checking it against a list will not protect an organization from the risks that come with maritime trade. Instead, stakeholders must adopt a proactive approach to KYV, which involves continuous monitoring and assessment of vessel behavior, ownership, and connections.
The industry’s response to this advisory will be critical in mitigating the risks associated with maritime sanctions evasion. By adopting a KYV approach, organizations can better protect themselves from the operational and reputational risks that come with maritime trade.
Original Article: Know Your Vessel™ is Highlighted in OFAC’s 2025 Advisory — Windward