August 19, 2020
By: Saskia Rietbroek, Executive Director, ACSS
After the U.S. government issued its Sanctions Advisory for the Maritime Industry in May 2020 (the ‘Maritime Advisory’), with heightened compliance expectations for commercial insurance, ship owners and others in the shipping industry, we at the ACSS noticed a need for further information on the topic. To that end, the Association of Certified Sanctions Specialists (ACSS) has recently conducted several outreach events for the global maritime shipping community.
The objective of these outreach initiatives was to provide information and materials designed to raise sanctions awareness and general sanctions resources that may be of interest to diverse players in the shipping community.
It’s all Greek to me – the ACSS Explains the Ins and Outs of the Maritime Advisory
The first program was conducted on June 18, in conjunction with the Hellenic Banking Association.
Myself, along with ACSS member Scott Nance, Principal at Langley Compliance Consulting LLC, presented on the ins and outs of the U.S. government maritime shipping advisory and its associated sanctions risks for the members of the Hellenic Banking Association.
The presentation, which was conducted virtually, covered the new compliance expectations and guidance from the U.S. government to counter illicit shipping and sanctions evasion. In this program, the speakers explained the measures to be adopted by those in the maritime sector, including: insurance companies; flag registry managers; port state control authorities; shipping industry associations; financial institutions; ship owners, operators, and charterers; classification societies; vessel captains; crewing companies; and commodity trading, supplier, and brokering companies.
75 participants attended the session from various Greek financial institutions. As Greece is a major player in the global shipping world, it was recommended that those Greek financial institutions that maintain accounts for companies and persons in the maritime shipping industry should take several new measures to mitigate the risk of sanctions violations. These measures, as well as what missteps to avoid, were explained at length.
In addition, the presentation covered lessons from real life enforcement actions against the maritime shipping industry and the five pillars of a sound sanctions compliance program.
Panama Presentation – the ACSS Reaches Out to the ‘Cross Roads of the Americas’
On June 19, a similar program on the new Maritime Advisory was conducted by the ACSS for the Panama shipping community, including officials from the Panama Port Authority, attorneys from the Panama Association of Maritime Law (APADEMAR) and members of the Panama Maritime Chamber of Commerce.
In this training and awareness program, which was conducted in Spanish, Saskia Rietbroek and Mitch Mejia represented the ACSS and were there to answer any questions.
One of the issues in the Maritime Advisory, which is particularly important for Panama, is the suggestion that flag registry managers should consider “requesting to join the Registry Information Sharing Compact (RISC) via a memorandum of understanding”.
This new information sharing agreement between the largest ship registries in the world, including Panama, the Marshall Islands and Liberia, has the potential to make it much more difficult for vessels to change their registration and easier for those in the maritime space to conduct due diligence.
This type of information sharing is important because illicit shipping companies have often engaged in “flag-hopping” to evade scrutiny. Re-registering the same vessel under different registries to continue to engage in sanction evasion activity.
Continued Support for the Maritime Sector
The ACSS intends to continue its work in spreading important knowledge to the global maritime and shipping sectors. This will involve further bespoke programs, webinars, virtual classes, and international conferences on the topic.