On the heels of its recent North Korean sanctions update, OFAC’s Syria update adds to the list of tactics used to obfuscate the destination and recipient of oil shipments ultimately destined for Syria. It emphasizes that parties in the petroleum shipping community should be mindful of the following practices:
- Falsifying cargo and vessel documents, including bills of lading, certificates of origin, invoices, packing lists,
proof of insurance and lists of last ports of call.
- Engaging in ship-to-ship (STS) transfers to conceal the origin or destination of cargo.
- Disabling the automatic identification system (AIS) to mask the destination of cargo destined for the government of Syria – vessels carrying petroleum to Syria have been known to intentionally disable their AIS transponders to mask their movements, which is a breach of international regulations.
- Changing vessel names to make identification more difficult and obfuscate prior illicit activity.