Risk management: predicting if a business partner is a potential sanction buster

Maritime security and intelligence company Dryad Global reports that three tankers have loaded in Iran and are sailing for Venezuela. The tankers are reported as Iranian-flagged MR1 oil and chemical tankers Forest (IMO: 9283760), Faxon (IMO: 9283758) and Fortune (IMO: 9283746). All three vessels have turned off their AIS transponders, and Dryad Global’s report said the tankers are expected to turn the AIS transponders back on to transit the Suez Canal before going dark again when approaching Venezuela.

“The vessels are believed to have conducted previous Iranian oil shipments in June this year,” Dryad said in its latest bulletin. Dryad Global’s assessment is that the potential attempt to export oil from Iran to Venezuela is part of a pattern, noting “two recent incidents add to the context of this resumption of exports”. “Firstly, in August, the US Justice Department seized the cargoes of four vessels which were linked to Iranian-Venezuelan oil shipments.

Secondly, the vessels in question which had their cargoes seized by the US were linked to Greek interests and companies, and in response Iran was quick to board Liberia-flagged MT Wila, which was also believed to be linked to the same companies (Palermo S.A).” The consequences from the US action in August are complex and still playing out with the potential for third-parties, such as financial institutions who handled payments, to face sanctions. Evidence of this possibility is the latest statement from the US Treasury OFAC department.

In a case going back to 2015, Deutsche Bank Trust Company Americas (DBTCA) made a US£583,100 settlement for apparent violations of US sanctions. In this case, DBTCA reportedly accepted verbal and email assurances that a sanctioned entity, IPP, was no longer involved in an oil deal. DBTCA agreed to process US£28M in payments for the fuel oil.

In the settlement, OFAC stated it “would have expected DBTCA take steps to corroborate independently the representations it received in order to assure itself that IPP did not have a present, future, or contingent interest in the payment it was requested to process, regardless of its time sensitivity.” Based on the OFAC ruling, DBTCA’s use of the traditional and often passive ‘knowing-your-client’ (KYC) checks utilised by several companies that undertake such pre-deal investigations was not enough. And the ruling raises the question of whether is it possible to predict sanction-based threats to an organisation.

Winward, the predictive maritime intelligence company, has announced the release of its next-generation maritime predictive intelligence solution powered by maritime artificial intelligence analytics (MAIA). Consisting of 10Bn datapoints and 300 behavioural analysis models, MAIA is designed to enable organisations to make smarter and faster decisions and optimise operations. According to Windward, MAIA screens, searches and analyses dynamic maritime data to “connect the dots” and discover potential risks and questionable business partners.

By continuously applying MAIA’s behavioural analysis models, the solution provides dynamic predictive intelligence based on vessel identity, cargo visibility, true location, voyage patterns, and more. Windward states that MAIA links this knowledge into patterns and profiles that create new insights and enable industry players to be proactive, ensuring they only do business with entities that comply with all the latest regulations. Windward chief executive Ami Daniel said of MAIA, “We are excited to usher in the era of Maritime 4.0, the next evolution of maritime intelligence empowering all stakeholders in the ecosystem.”

“Risk management lies at the core of any business operation, and maritime is no exception. With our predictive intelligence solution, we are giving authorities, banks, insurers, shipping companies, and others the most comprehensive view of maritime risk and enabling the highest level of accountability and transparency.” Voyage irregularities is one of the many new features powered by MAIA, providing clients with a 360? smart profile of each entity to bring transparency and accountability to the global maritime grid.

Windward’s predictive intelligence predicts inconsistencies and behavioural irregularities, including the vessel’s age, ship-to-ship transfers, course deviations, transmission gaps, flag hopping, and more.

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This includes the Maritime Cyber Risk Management Forum on 2 November 2020.

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