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US Shipping Advisory: Guidance for Port State Control Authorities

Guidance for Port State Control Authorities
Port state control authorities and relevant customs authorities may wish to consider implementing the following due diligence practices to the extent they deem such practices appropriate and helpful in assessing and mitigating sanctions risks and consistent with local laws and regulations.
 Requiring vessels arriving in port to maintain AIS broadcasts, as provided for in SOLAS.
 Notifying relevant parties, including ship captains, managers, and others, that disablement or manipulation of AIS inconsistent with SOLAS is an indicator of possible illicit activity and could be investigated by competent authorities.
 Denying port entry to ships with a history of AIS disablement or manipulation inconsistent with SOLAS.
 Reviewing bills of lading to confirm origin of the cargo. Bills alleging oil, petrochemicals, fuel, and metals from areas determined to be high-risk for sanctions evasion should be reviewed with particular due diligence.
 Requesting and reviewing complete and accurate shipping documentation, including bills of lading identifying the origin of cargo for individuals and entities processing transactions pertaining to shipments involving products going to or from Iran, North Korea, and Syria. As is generally the case, such shipping documentation should reflect the details of the underlying voyage, including the vessel(s), cargo, origin, destination, and parties to the transaction. Any indication of manipulated shipping documentation, whether in connection with these or other areas, may be a red flag for potential illicit activity and should be investigated fully prior to providing services.
 Ensuring employees of the port state authority who reveal illegal or sanctionable behavior are protected from retaliation, and ensuring there is a confidential mechanism to report suspected or actual violations of law or sanctionable conduct.
 Incorporating data such as historical ship location, ship registry information, and ship flagging information, along with available information from the U.S. Department of the Treasury, the UN, and the U.S. Coast Guard, into due diligence practices.
 Circulating information about an award offered through the Rewards for Justice (RFJ) program that offers rewards of up to $5 million for information that leads to the disruption of financial mechanisms of persons engaged in certain activities that support North Korea, including illicit shipping activities, money laundering, sanctions evasion, cyber-crime, or weapons of mass destruction (WMD) proliferation. For more information, or to submit a tip, visit http://www.rewardsforjustice.net or e-mail northkorea@dosinfo.com.
 Circulating information about an award offered from the RFJ Program of up to $15 million for information leading to the disruption of the financial mechanisms of Iran’s Islamic Revolutionary Guard Corps (IRGC) and its branches, including the IRGC-Qods Force (IRGC-QF). For more information, or to submit a tip, visit https://rewardsforjustice.net/english/irgc.html.

Categories: Advisories OFAC Updates

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