Guidance for Crewing Companies
Crewing companies 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.
Being aware of, and ensuring your crewmembers are aware of, the IMO circulated guidance in relation to illicit shipping and why these practices are unsafe.
Communicating to clients that the ships your crews will be operating will be monitored for AIS disablement and manipulation, and that such instances will be investigated.
Researching your prospective vessel’s AIS history to help determine whether the vessel may be involved in illicit activities.
Ensuring employees 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.
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 email@example.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.