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Combatting a new era of maritime sanctions evasion

Recent years have seen a notable increase in deceptive shipping practices (DSPs), particularly in the form of AIS spoofing and dark fleet activity. The implementation of Russia-related sanctions and a price cap on the sale of Russian oil and petroleum products has led threat actors to turn towards more sophisticated forms of sanctions evasion. Their aim is to deceive authorities and financial crime compliance programs via the creation of a shadow economy that operates outside of the confines of US, UK, EU, and G-7 law.

Despite the new era of sanctions compliance challenges that such DSPs have created, it is possible to comprehend, detect and mitigate these practices, as Charles Ike, Vice President of Maritime Trade Sales, Pole Star Global, explains…

The challenge: maritime sanction evasion

Sanctions targets require access to allied countries’ markets, including commodities traders; financial institutions; flag registries; and ship charterers (“covered persons”) – all of whom have compliance obligations, including those relating to the price cap on Russian oil.

The Office of Foreign Assets Control (OFAC) and other sanctions authorities have outlined an attestation process to document that Russian oil sales are within the Price Cap.  However, this is not a mere record-keeping problem. The current price cap for oil leaves very little room for margin, meaning threat actors may attempt to falsify documentation, pass goods off as being of non-Russian origin, or violate other sanctions outside the Price Cap – such as acting on behalf of a blocked party or attempting to export oil to an allied country.

The authorities have therefore warned covered persons to be aware of evasion attempts. For instance, in April, OFAC singled out P&I clubs, ship owners, flag registries, and commodities brokers to remain vigilant for DSPs as evidence of sanctions evasion.

In addition, the UK’s National Crime Agency has warned the wider financial community that sanctions targets may use proxies and enablers to gain access to the financial system – access they would otherwise be denied. This advice is equally applicable to the maritime industry.

Illicit dark fleet activity 

There are two primary methods emerging for sanctions evasion: the “dark fleet” and “AIS spoofing”.

The dark fleet is a fleet of tankers owned and operated by persons outside of allied jurisdictions. These tankers – estimated to number around 600 vessels globally – are acquired for trading with Russia or other sanctioned countries.  Owners will go to great lengths to disguise their stakes in these vessels.

That said, dark fleet vessels are not used exclusively for sanctioned trade – and not all vessels will therefore present the same level of risk. For instance, they may be shipping oil within the confines of the Price Cap. However, they do present an increased risk to covered persons. Covered persons should therefore proceed cautiously when dealing with a dark fleet vessel and conduct enhanced due diligence on the provenance of the cargo, the buyer and the seller.

Determining whether a vessel is part of the dark fleet is a subjective process.  A number of criteria and factors must be considered before a ship can be categorised:

Ownership: A vessel’s owner may be tied directly to Russia, Iran, or Venezuela. Likewise, threat actors may attempt to obfuscate their interest by owning the vessel through shell or front companies, or by making rapid changes to a vessel’s declared owners and operators.

Movement: Dark fleet vessels may frequent Russian or sanctioned ports with deliveries to non-allied countries, and/or conduct ship-to-ship transfers in known high-risk zones, such as those used off the coast of Greece.

Deceptive Practices: Consideration for vessels who engage in AIS spoofing or who opportunistically turn off their AIS transponder with the intent of avoiding sanctions.

Timing: The timing of a vessel’s ownership change may indicate an intent to evade sanctions. For instance, moving vessels to new owners directly after the Russian price cap was passed. Likewise, if a vessel makes its first voyage – or routinely makes the same voyages – to Russia or a sanctioned country, this may indicate the vessel was purchased for sanctioned trade.

Fleet coordination: Consideration of a vessel’s changes in conjunction with other vessels owned or operated by the same person. If a fleet of vessels change their flag simultaneously or incorporate into a new high-risk jurisdiction, this may signal that the owner and operators intend to misuse the vessel.

Finally, covered persons should also be aware of the increase in pop-up P&I clubs, outside of the recognised International Group consortium. Thorough and intensified due diligence on the vessel’s owner, operator, or charterer, as well as the source of the cargo, is recommended.

The rise of AIS Spoofing 

Spoofing was once considered a minor part of maritime sanctions evasion, but in the past six months, the practice has surged ahead to become the predominant form of evasion – at least for vessels carrying high-value cargoes such as oil and petroleum products.

In the past, high-risk countries would simply prohibit the export of AIS data, and compliance officers denied access to AIS information. These gaps in AIS coverage were easy to spot. In reaction, there’s been a major shift toward deceptive strategies, which is the provision of false AIS information. That is, inaccurate positional and navigation data is given, making  a vessel appear where it is not.

This presents a far more difficult problem for the maritime community to tackle because threat actors have access to a broader range of spoofing techniques, and maritime intelligence firms will need to keep up with those tactics to counter them. OFAC recommends insurers, flag registries, and ship managers turn to “maritime intelligence services to improve detection of AIS manipulation”.

False AIS data can be uploaded through a variety of means and can be targeted towards individual AIS ground stations and data providers, or through radio frequency broadcasts targeting satellites. Typically, an AIS position is broadcast from a vessel’s transponder, which is then received by either a terrestrial ground station (“T-AIS”) or an overhead satellite (“S-AIS”). This information is then transmitted digitally – such as through an API – to either an AIS aggregator or directly to a maritime intelligence provider.

A threat actor can insert its false data at any point in this chain. Yet, with the right security protocols or an automated ability, receiving sources can discriminate between valid and invalid transponders.

In general, spoofing can be categorised into four typologies, each having distinct signatures:

  • Anchor spoofing” simulates the vessel remaining in the same place for impractical amounts of time. The vessel may appear to be at anchor or may look like offshore storage. However, a review of the vessel’s signal activity or use of human or imagery sources allows us to confirm that it is not the transmitted location.
  • “Circle spoofing” describes a situation where the vessel moves in geometric circles at a set location. Circle spoofing is generally used closer to shores and ports over a few days to a week – which is enough time to visit a sanctioned port and return to the station.
  • “Slow roll spoofing” is when the vessel pretends to be moving in a general direction of travel at very slow speeds. This movement will lack an economic purpose and/or be inconsistent with local traffic patterns.
  • “Pre-programmed route spoofing” is the most realistic technique used. The vessel is programmed to travel along feasible routes. This requires either duplicating or sourcing past AIS data to successfully mimic      the vessel’s movements, or more careful planning is used to ensure that the route appears to have an economic purpose. This methodology is hardly infallible, but is difficult to identify based on a visual inspection of the underlying data.


The threat of maritime sanctions evasion has increased tremendously over the past year. We are now seeing the wholesale creation of fleets for side-stepping allied sanctions, a drastic increase in AIS spoofing and more complex forms of maritime sanctions evasion.

With the threat environment only likely to increase; the onus is on covered persons and those involved in sanctions enforcement to conduct enhanced due diligence on all transactions involving potential dark fleet vessels and eschew – if possible – transactions involving the highest risk fleets, jurisdictions, flags, and classification societies. Working in partnership with providers of maritime intelligence services will be key to ensuring the most up-to-date data is used as part of this due diligence.

Photo by Kurt Cotoaga on Unsplash

Building the business case for Satellite IoT 

The Operational IoT market continues to expand as organisations across the world imagine an extraordinary range of opportunities to leverage sensor technology. Weather monitoring stations are transforming the efficiency and environmental performance of remote copper mines and helping farmers to safeguard crops and livestock in a changing climate. The shipping industry is improving cargo traceability to mitigate on-going disruption. Charities are monitoring water quality across Africa to ensure remote communities have reliable access to safe drinking water.

With the arrival of robust, proven, cost-effective satellite connection, the true potential of these IoT applications can be realised. With estimates suggesting there will be tens of millions of satellite IoT devices in use by 2030, access to reliable, global coverage is now enabling new opportunities for systems integrators (SIs) across the world.

It is now time for SIs to build a business case for Satellite IoT, says Eric Ménard, Vice President Strategy and Business, Astrocast…

Market Expectation

Satellite connectivity may have been available for years, but the market has been waiting for a satellite connection designed specifically for widescale IoT deployment. Many of the key target applications – from agriculture to supply chain – do not require the continuous or real-time communication associated with high-cost legacy satellite connectivity. These solutions  play a critical role but they are too expensive and power hungry to support a compelling business case for most Operational IoT deployments.

A farmer requires only daily or twice daily updates of cattle location to track herd health. A copper mine uses intermittent updates on the water table level to provide operational visibility and meet environmental regulation. A shipping line does not require real-time updates of the temperature of its containers . Transmitting data either once or twice a day – or taking multiple recordings which can be buffered and uploaded every 12 hours – is perfectly adequate.

The value of this data is significant – especially in areas such as shipping. The use of IoT sensors can ensure high value cargo, including pharmaceuticals, are kept at the right temperature and left untampered. Any deviation will prompt an alarm and allow remediation where possible, resulting in less wastage and better integrity.

Building Confidence

However, while the business case is compelling, such IoT operations are incredibly cost sensitive. When a deployment may extend to tens of thousands, even hundreds of thousands of devices, small differences in performance and lifetime will fundamentally change the return on investment (ROI). The business case becomes even more sensitive when extended to remote areas without terrestrial network coverage and require satellite connectivity. How can the sensors be deployed to remote locations cost effectively? What is the cost of satellite transmission? How long must the battery last on a sensor to ensure the ROI is not compromised? Plus, how can the data be collected and used to drive tangible commercial benefits?

Even before exploring the technology, SIs need robust due diligence to ensure confidence in the business credibility and model of the satellite provider. Ensuring excellent satellite coverage, including across international water, is essential. Business longevity is also fundamental for deployments that could be in the field for a decade.

In addition to verifying strong financial credentials, it is also important to assess the billing model, contractual arrangements, warranties and support structure. Is the company committed to supporting its SIs not only in the prototyping and field-testing phase, but also through industrialisation, production and taking the solution to the market? Each stage of this process will raise new challenges. Having a partner in place with both the knowledge and commitment to overcome problems will transform the likelihood of commercial success.

Proof of Concept

Only once the foundations of a business case have been confirmed should an SI make the investment in a technology assessment. For many SIs looking to expand existing IoT solutions, speed of integration is an important consideration. From the quality of documentation to availability of training, the way a satellite company works with its SIs to ease the integration of SatIoT in to the existing IoT solution set can make a significant difference in time to market.

For the past few years, a number of innovative SIs have been testing the latest generation of cost- effective SatIoT connectivity to determine the viability and requirements of an industrial scale deployment. They have built prototypes and invested in field testing. The process has highlighted the importance of ultra-low battery consumption to minimise the need for replacements in situ. Typically, a business case may only stand up if the battery lasts five to ten years. In some locations, the Satellite IoT solution can be integrated with a solar panel, overcoming the need for a dedicated battery.

SIs have also worked closely with SatIoT providers to optimise antenna design and ensure the antenna is both reliable and easy to integrate. A small, flat antenna may be essential but additional questions will arise specific to an area of deployment. For example, lightweight but robust enclosures are now used to securely attach an antenna to livestock to track their movement across remote farmland and identify any that leave the herd, indicating ill-health or injury. Or a simple addition of a Bluetooth connection between the device and the SatIoT antenna provides an excellent solution to achieve indoor satellite IoT deployments in rural locations with no terrestrial networks.

The availability of bidirectional connectivity also provides SIs with a future proofed solution. Updates can be downloaded remotely to the sensors as required – for example, if a customer wants to change the frequency of data recording.


These innovators have led the way, discovering how to optimise SatIoT solutions and antenna design to deliver a robust, viable and cost-effective deployment. Critically, these companies have proved the business case for Satellite IoT. While the demand was never in question, the technology is now in place to enable it. Whether it is shipping containers or agriculture or environmental monitoring or animal tracking, SatIoT developments are now moving into the next phase of industrial scale deployment.

And this is just the start. The shipping industry, for example, has an array of complex operational challenges in its management of 50 million containers across the globe. Tracking location and temperature monitoring are delivering financial benefits. Adding the ability to identify whether a container has been entered or tampered with during the voyage, will support the war on piracy and drugs. Adding smoke detectors will raise the alarm when fire breaks out on board – an increasing concern if owners fail to inform the shipping company that the container holds self-combusting cargo, such as Lithium-Ion batteries.

The door is open for SIs across the world to build on the knowledge gained over the last few years, explore the global reach of cost-effective satellite connections and build a compelling business case for Satellite IoT solutions that will transform operational efficiency for organisations of every size across the world.

DOWNLOAD: Shipping and Distribution – The State of the Deskless Workforce

Are staffing problems leaving your business high and dry? Download Quinyx’s new report for invaluable employee retention and scheduling advice. 

Current worker shortages in the UK are continuing to cause problems. Many firms are desperately trying to avoid business disruption as they attempt to plug staffing gaps, whilst running the risk of overworking existing team members too.

Workforce management solution provider Quinyx has released a new report aimed at leaders within the shipping and distribution sectors. Full of useful tips and advice on staff scheduling and employee engagement, the report outlines findings from Quinyx’s recent study of ‘deskless’ workers in the industry, highlighting what matters most to employees.

As the sector faces uncertainty following COVID-19 and Brexit, looking after loyal staff has never been more important. Quinyx’s report contains key insights on employee retention, plus details of how managers can implement scheduling processes to make day-to-day operations run more smoothly.

Download your free copy here.

WEBINAR: Managing cost volatility with forecasting – a practical roadmap with SLG Brands

By Zencargo

With global shipping costs inflated to unprecedented highs, getting a total view of the costs of your supply chain has never been more important for a business.

In fact, in a recent roundtable of 25 supply chain leaders[1], 56% said that ‘improving overall data quality for more informed decisions’ was the one approach that would make the most impact on their business.

But building out a forecasting process that delivers results takes time – not to mention the PO management foundations you need to lay before you even start to implement forecasting. To make implementation as smooth as possible, you need a roadmap.

Over the last six months, SLG Brands, the company behind some of the high street’s most fashionable beauty brands,has undertaken extensive work around PO management, as well as forecasting freight spend and container usage – all of which has helped to manage a lot of risk and uncertainty. 

In this upcoming webinar, Devinder Chana, SLG’s Director of Supply Chain, explains to Zencargo’s Scott Irvine exactly how they are tackling their forecasting project: from planning the project to focusing on data health.

In the webinar, Scott and Devinder will cover:

  • Why SLG wanted to implement better PO management and cost forecasting
  • What you need to get started on your path to better cost visibility
  • The main stages in your forecasting roadmap
  • The advice Devinder would give to other businesses that are expanding their forecasting ability

If you’re looking to cut the risk of cost volatility, make sure you book your place now.

ABP invests in Port of Lowestoft to support UK Southern North Sea energy sector

Associated British Ports (ABP), the owner and operator of the Port of Lowestoft has invested more than £250,000 in the construction of a new fuel bunkering facility to support the UK Southern North Sea (SNS) energy sector.

Yesterday, the bunkering facility received its first fuel from the vessel, Thun Grace, which called at the Port of Lowestoft on behalf of Peterson UK and GEOS Group as part of a strategic partnership to carry out fuel services. GEOS Group provides fuel directly from a UK refinery to various ports around the UK.

John Shade, UK Fuel Manager, said: “This new fuel bunkering facility provides operators from the oil and gas and offshore wind sectors with another reason to use Lowestoft as their port of choice, with capability and capacity now in place to service any vessel that comes into the port. We are pleased to have worked in partnership with ABP and GEOS Group to create a competitively priced solution in a very convenient location.”

Barry Newton, Director, GEOS Group, added: “We are delighted to be able to provide a fuelling facility in Lowestoft, both supporting and adding to port services, and are excited to work with ABP in the development of the port going forward.”

Construction of the new facility, which included the raising of bund walls, began in November 2019 and was completed on schedule by the local contractor Brooks and Wood.

Paul Ager, ABP Divisional Port Manager – East Coast, said: “Today marks another important milestone in our partnership with Peterson UK and GEOS Group, which will help support jobs and the regional economy at this vital time.

“With this new bunkering facility our marine teams are able to support the UK SNS energy sector 365 days a year, making sure that our customers get a consistent, cost-effective and efficient service.”

Since the start of ABP and Peterson UK’s long-term business partnership in January 2019, the two companies have celebrated a number of successes, including reaching the milestone of handling 100 vessels in October 2019. Since then, this figure has grown to more than 350 vessels, which have called at the port.

Peterson UK operates a wide range of warehouses and other cargo and logistic services from the Port of Lowestoft, including fuel bunkering to support the oil and gas and renewable energy sectors being supplied from its Lowestoft Supply Base.

New container shipping association established

A.P. Moller – Maersk, CMA CGM, Hapag-Lloyd, MSC and Ocean Network Express plan to establish a new container shipping association.

The move is intended to ‘pave the way for digitalisation, standardisation and interoperability in the container shipping industry’.

In addition, IT executives from A.P. Moller – Maersk, CMA CGM, Hapag-Lloyd, MSC and Ocean Network Express are discussing the creation of common information technology standards which will be openly available and free of charge for all stakeholders of the wider container shipping industry.

“It’s in the customers’ and all stakeholders’ best interest, if container shipping companies operate with a common set of information technology standards”, said André Simha, CIO of MSC and spokesperson of the group.

“We are striving for less red tape and better transparency. The timing is right, as emerging technologiescreate new customer friendly opportunities. Together, we gain traction in delivering technological breakthroughs and services to our customers compared to working in our own closed silos.”

The shipping industry already has multiple organisations and associations, but the new group’s members say they’ve identified a need for a neutral and non-profit body for ocean carriers that is driven by delivering benefits for the industry and its stakeholders.

The new association claims it has no intent of developing or operating any digital platform, but aims to ensure interoperability through standardisation. Similarly, the association will not discuss any commercial or operational matters.

BIFA reasserts call for an end to shipping line surcharges

The British International Freight Association (BIFA) is repeating the calls it has made previously for an end to surcharges imposed by shipping lines.

The latest call follows recent announcements by the world’s leading container shipping companies almost in unison that they would be levying “emergency” bunker surcharges in response to rising fuel costs.

Robert Keen, BIFA Director General, said: “Forwarders do not like shipping line surcharges of whatever nature and we have been challenging their legitimacy on behalf of our members – and their customers – for many years.”

“In the past, we have seen equipment imbalance surcharges, peak season surcharges and currency surcharges, in addition to fuel surcharges.

“The number of surcharges and fees continues to grow – often with no real explanation or justification. For instance, what does an extra ‘administration fee’ or ‘container sealing fee’ cover that is not in the standard service offered?”

BIFA explains that shippers can also be asked to pay surcharges when there is port congestion caused by labour unrest or bad weather, or haulage surcharges when there is a shortage of HGV drivers.

Forwarders do all they can to minimise the effects of the surcharges but in the end at least some of the costs need to be passed on to the customers “and there is sometimes an unfair perception that our members are to blame,” Keen added, before concluding: “If a shipper enters a contract to buy goods they should know exactly what they are paying and that price should not change. If they use Incoterms they can buy ex works or FOB and control the supply chain. If they let their supplier arrange shipping, they have no control over the charges applied. But in either case, additional surcharges imposed by shipping lines should not be allowed.”