Page 57: of Maritime Reporter Magazine (August 2020)

© freshidea/AdobeStock to come out, organizations can become However, operating this function re- sory is to work towards the elimination exposed to the potential risks that oc- lies on information, and it can’t be done of money laundering and fraud, but this cur in real time. In order to protect their manually given the vast network of will require everyone in the trade sup- business and its reputation, it is impor- shipping routes, ports, ships, and other ply chain to operate with the same, or tant for them to be proactive in spotting business in the network. near same, due diligence that has been red ? ags themselves. Outsourcing this intel, and the tech- expected of the ? nancial institutions ? -

A further example is that a vessel nology needed to monitor and identify nancing the trade. named “ASIA HONOR” was not listed red ? ags is likely to be the most cost- This will be a big change for many, on the February 2018 advisory, even effective way of doing that. Sophisti- but as with most risks, they are man- though it had visited the port of Na- cated trade compliance software can ageable with the right combination of jin, North Korea on June 23rd, 2017 - spot such activity and alert the organi- information, insight, and application. something that could have been veri? ed zation to the risk, even if the regulator Shipping organizations should rightly through wider networks and tracking. does not. take a moment to assess their posi-

Some of the risk patterns OFAC has tion, but while the new advisory clearly

A new approach called out suggests that a more prudent shows OFAC’s increased scope in en-

For companies new to enhanced due approach to identifying risks related to forcing compliance, it also helps lay the diligence and compliance, these chal- trade is needed. This goes beyond the route map to success for the organiza- lenges are daunting. First and fore- complex due diligence that must be tions most impacted. most, internalizing and institutionaliz- conducted prior to agreeing to ? nance a ing sanctions compliance is key. This transaction, and requires ongoing vigi-

The Author means operating a robust compliance lance to identify other red ? ags, such function and having someone respon- as when a ship approaches a sanctioned sible for consistent monitoring, evalu- or high-risk port or when they turn off

Loeser ation and implementation of a compli- their AIS tracker.

Dave Loeser is ance program. This will be the ? rst step

Senior Director towards meeting all the guidelines in The future of Product Strat- egy for Accuity. the current advisory. Ultimately the goal of OFAC’s advi- www.marinelink.com 57

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