OFAC’s Latest Maritime Advisory: Behavioral Risk Takes Center Stage
In its latest maritime sanctions advisory, the U.S. Treasury’s Office of Foreign Assets Control (OFAC) has elevated behavioral risk to stand alongside entity-based risk as a primary compliance concern. This builds on its 2020 guidance, which first classified deceptive shipping practices like AIS manipulation, ship-to-ship (STS) transfers, and false flagging as core red flags.
The advisory’s primary updates include the expectation of proactive detection and investigation. OFAC is no longer satisfied with reactive screening, meaning that organizations are now expected to document how they identify and address high-risk behaviors before they escalate into violations. Behavioral red flags carry equal weight with sanctioned entity matches in enforcement actions, and documentation is mandatory for legitimate AIS disablement and other operational anomalies.
This shift reinforces that compliance is no longer just about who a vessel is – it’s about how it behaves over time. For maritime stakeholders, that means investing in systems that can detect patterns like location (GNSS) manipulation, identity laundering, and concealed port calls in near real-time.
EU’s 18th Sanctions Package: A New Layer of Complexity
The European Union’s latest sanctions on Russia introduce some of the most sweeping maritime compliance measures to date, directly targeting flag registries, expanding the dark fleet list, and tightening enforcement on oil price caps. Key shifts include the direct targeting of flag registries, Gabon and Comoros registries sanctioned for enabling opaque and high-risk Russian oil transport, with over 130 flagged vessels already under Western sanctions.
The EU has also expanded its dark fleet list by 105 new tankers banned from EU ports, all flagged by Windward as high-risk before designation. Additionally, the dynamic price cap mechanism sets a new $47.60/bbl cap for Russian crude starting September 3, 2025, revised every six months. Furthermore, the ban on refined products from Russian crude is effective January 21, 2026, even if processed in third countries.
These changes mark the EU’s most aggressive stance yet, widening its compliance net to include not just vessels and owners but the commercial ecosystem that sustains sanctions evasion.
Original Article: Sanctioned Tankers With False Flags Test Europe’s Resolve — Windward