Information Helpful to Financial Institutions to Assess the Risks of their Maritime Industry Customers
Similar to the customer due diligence approach conducted for any customer, financial institutions should rely on their internal risk assessments for customers in the maritime industry, in order to employ appropriate risk mitigation measures consistent with applicable existing U.S. laws and regulations
designed to combat money laundering and terrorist and proliferation financing.
This approach to
compliance may include appropriate due diligence policies and procedures as required by law and
regulation, such as, where applicable, FinCEN’s customer due diligence and beneficial ownership
Risk factors that financial institutions may wish to consider as a part of that assessment include, but are not limited to:
Identifying commodities and trade corridors susceptible to transshipment and ship-to-ship transfers and the extent of their use by an institution’s maritime industry customer.
Results from an assessment of the nature of each client’s business, including the type of service(s) offered and geographical presence.
Client activity for transactions inconsistent with the client’s typical business practices, to include when clients acquire new vessels.
Client acquisition or sale of vessels to determine that the client’s assets do not include blocked property.