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Maritime Sanctions Due Diligence

Maritime sanctions due diligence for compliance desks: a tanker’s papers tested against each other and against her track, with a signed, cited answer before the fixture offer lapses.

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Follow one fixture offer from 09:40 to 11:52 ↓

The problem

A broker’s offer with a noon deadline, and the papers in five places

A broker offers a ship and the desk fixes her subject to compliance screening, with a time on it. Chartering emails compliance the ship’s name. The analyst runs her number and owner through a list screening service. Then she opens the registry extract, insurance certificates, class status and owner’s questionnaire one by one, and checks the last voyage in a tracking tool.

Each paper looks fine on its own. The warning is in the disagreement between them, and that only shows when someone lays them side by side. An owner nobody could name gets skipped in a free-text approval email, a screening with no list match reads like a clearance, and the reasons stay in an inbox where an auditor cannot tell who read what.

Built forSanctions analystsCompliance officersChartering managersInternal auditors

The Problem Today

Warning signs sit on different papers, and the offer expires before anyone lays them side by side.

2,000: tons of oil cargo: above it, a state insurance certificate published
300: gross tonnage and up: ships on international voyages carry AIS published

Read one by one today

Registry
Insurance
Class
Positions

Positions checked lastGaps and draft changes go unmeasured
Unnamed owners go unwrittenA list with no match reads like a clearance

The Solution

Each paper gatheredRegistry, insurance, class and positions, tied to one ship number
Papers tested in pairsRegistry against insurance, class against owner, voyage against track
Gaps measuredHours, miles, speed and draft before and after, with the sum shown
An officer decidesClear, escalate or decline, after opening each paper behind a warning

Built-in controls

Agents never clear a ship or a cargo
A second person opens and signs each decision
A failed check leaves the ship not cleared

What You Get

Compliance gives a signed, cited answer before the offer lapses, and chartering knows where it stands.

A record in the analyst's wordsOne cited sentence for each finding
Open owners written downNo match is not read as clear
Rescreened after list updatesUnchanged ships renewed on a sampled sign-off

One offer, two hours

Maritime sanctions due diligence on a crude tanker offered at 09:40

A broker offers an older crude tanker for a 700,000-barrel cargo, firm until noon, subject to the charterer’s compliance screening. Her papers came with the offer.

demoEvery ship, company, registry and person here is fictional sample data, and the sample ship numbers start with 0, so none is a real ship.

0109:52
Twenty-three screenings open, and this one has 2 h 8 m left
Sanctions analyst
The queue lists every open screening with its clock: fixtures by the offer time, cargo purchases and nominations by the end of the day, rescreen changes after a list update. For this tanker the agents already found three pairs of papers that disagree, three flag changes, two owners left open and a 31-hour gap. No list match. Nothing is cleared yet.
0209:52
Three pairs of papers disagree, and two owners stay open
Sanctions analyst
The ship sits in the middle with each paper around her: registry, insurer, class society, manager, sanctions lists, the position gap. Lines show where two papers agree and where they disagree. Beside it, eight tests, each naming the two papers it compared. Whoever owns the shareholder is named in no paper, so the list screener could not screen them.
0309:55
The registry names one owner; the insurance certificate names her previous one
Sanctions analyst
Side by side, the registry extract shows the current owner since August, and the only state insurance certificate on file names a different company and was issued by her previous registry. No certificate from the current registry is in the file. The test says the papers disagree, and the passages are lit on both.
0410:00
Dark for 31 hours on a ballast passage, then 4.2 m deeper
Sanctions analyst
The track shows twelve months of position reports with every gap of six hours or more. Two are small and explained or show no change. The third runs 31 hours, 46 nautical miles at 1.48 knots against 11.8 before, with no port call, and the reported draft goes from 9.6 to 13.8 m. The owner declared that voyage in ballast. A signal, not proof, the screen says.
05Before 11:21
Her record in her own words, with what nobody could see kept apart
Sanctions analyst
The agent drafted four cited sentences on what the papers show and a list of what could not be seen: who owns the shareholder, who stands behind the corporate director, whether crew-typed drafts are right. She writes the summary herself and proposes decline. Clear is not offered here, with three pairs of papers disagreeing and an owner unnamed.
0611:21
Each warning opens to both papers behind it before she can decide
Compliance officer
The officer’s decision lists the record and each warning test, and each has to be opened before any decision button works. Here she has opened the record and is on registry against insurance, with both papers in full. Next come class against ownership, flag and name history, and the declared voyage against positions.
0711:52
Declined at 11:52, with five of five opened
Compliance officer
Five items opened, and the decision is recorded with its reason: papers disagree and were not explained in time, proposed by the analyst. Chartering sees not cleared and cannot override it. A new offer with new papers is a new screening, and the audit trail holds every opening.
0811:52
Chartering sees not cleared, and never the record or the papers
Chartering manager
The chartering desk gets a plain status per ship: cleared, with compliance, not cleared, or a check that could not run. It can lift a compliance subject only on a cleared ship, ask for broker wording that shares no reasons, or offer another ship for screening. The answer arrived eight minutes before the offer lapsed.

Three things the papers say only when laid side by side

None of them is a list match. Each needed two papers or a paper and the track.

Two owners on two papers

The registry and the only insurance certificate name different companies.

Class moved before the sale

Class left the association weeks before the bill of sale, and the new letter named the buyer early.

A ballast passage that loaded

Thirty-one hours dark, 4.2 m deeper after, and no port call on the way.

demoSample data, from the working solution.

Around the screening

Flag history, ownership layers and the deceptive shipping practices trail

The rest of the compliance desk’s screens on this one tanker.

Flag and name history of a tanker: registry, class, owner, insurer and manager changes over fourteen months, each with its paper — **Flag and name history**Name, flag, class, owner, insurer and manager over time, with every change and its paper. Three flags in 14 months against a rule of more than one in 24.

Broker’s fixture offer email firm until noon, kept in the screening file beside the list of papers received — **The offer and its clock**The broker’s email, firm until noon subject to compliance screening, kept in the file. Beside it, every paper the screening holds.

Tanker ownership check: owner, shareholder and director layers with unnamed nodes, and the manager’s other ships with a rescreen hold — **Who stands behind her**Owner layers as far as the papers go, with open nodes that cannot be screened. The same manager runs another ship already cleared, now proposed for rescreen.

Audit trail of one screening: analyst’s proposal, each paper the compliance officer opened, the decline and the chartering status — **Who opened what before signing**The proposal, each paper the officer opened, the decline with its reason, the chartering status and the rescreen proposal, in order.

Screening rule settings: gap at sea that counts, flag changes, class outside the association, insurance rule, fail closed locked on — **The customer’s screening rule**Which gaps count, which flag changes count, class outside the association, insurance naming the registered owner, and fail closed, which cannot be switched off.

demoSample data, from the working solution.

The analyst proposes, the officer decides, counsel rules on escalations

Nobody decides their own proposal.

Sanctions analyst

Sees: The papers, the tests, the track and the queue
Signs: Writes the record and proposes; places holds

Compliance officer

Sees: The record and both papers behind each warning
Signs: Clears, escalates or declines; signs bulk renewals

Sanctions counsel

Sees: Escalated questions with the papers
Signs: Rules on possible list matches and ownership questions

Chartering manager

Sees: A status per ship
Signs: Lifts subjects on cleared ships; never overrides

Internal auditor

Sees: Every opening and decision, read only
Signs: Nothing; downloads who opened what

The agents

Papers read and tested by agents, and none of them can clear a ship

They gather, read, test, trace and draft. People decide.

Intake agent

Opens a screening and gathers the papers from email, documents and data services.

Never writes to a broker or owner

Paper reader

Reads each paper into fields tied to the ship number, each value cited.

A blank stays blank

Paper tester

Tests papers in pairs: registry against insurance, class against ownership, flag history.

Never decides which paper is true

Track reader

Reads twelve months of positions, finds gaps, draft changes and near-stops, and does the sums.

Never calls a gap proof

Ownership tracer

Builds owner layers and the network of shared managers and directors.

Never fills an open node from a guess

List screener

Screens the ship number, every name and company against your lists, with near matches.

Never rules on a near match

Record writer

Drafts the record in plain words and a proposal for the analyst.

Never says a ship is clean
Never clears anything

What compliance desks ask about maritime sanctions due diligence

What is maritime sanctions due diligence?

Maritime sanctions due diligence is checking a ship, her owners and her voyages before you fix or buy a cargo on her. This solution gathers the ship’s papers, tests them against each other and against her position history, writes down what nobody could see, and leaves the decision to a compliance officer who has opened the papers.

Is vessel sanctions screening enough on its own?

No match on a list is not a clearance when an owner layer is unnamed. The list screener runs every name and company it can, and the record says plainly who could not be screened.

Which deceptive shipping practices does it look for?

It tests what papers can show: owners that differ between registry and insurance, class moves around a sale, frequent flag and name changes, and gaps in position reports with draft changes that do not match the declared voyage.

How does AIS gap screening work here?

The track reader lists every gap at sea longer than your rule, with hours, miles, speed and draft before and after, and any port call. Reported drafts are typed by crews, so a gap with a deeper draft is a signal, never proof.

Does it help with ship-to-ship transfer due diligence?

A loaded draft after a gap with no port call is exactly what the track test flags, set against the owner’s declared voyage. Who the other ship was is not in the papers, and the record says so.

What if a check cannot run before the offer lapses?

The ship stays not cleared. Fail closed is locked on: a check that cannot run, an unanswered question or a lapsed clock leaves the answer at not cleared.

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