STEAMSHIP MUTUAL UNDERWRITING ASSOCIATION LIMITED Authorised by the Prudential Regulation Authority and regulated by the Financial Conduct Authority and Prudential Regulation Authority (Registered in England and Wales – Registration number 105461. PRA and FCA registration number 202548) MANAGERS: STEAMSHIP P&I MANAGEMENT LLP SPIM is an appointed representative of Steamship Insurance Management Services Limited which is authorised and regulated by the Financial Conduct Authority (Registered in England and Wales – Registration Number OC376859. FCA registration number 597046) Sanctions’Recent Deceptive Practices February 2022 To the Members Introduction Since 2010, considerable sanctions’ activity has been directed at shipping and its supporting industries reflecting the fact that 90% of world trade involves the carriage of goods by sea. The purpose of this Circular is to draw Members’ attention to some of the recent deceptive practices employed by parties that are engaged in activities that offend the sanctions regimes operated by national governments and/or supranational bodies such as the United Nations. Current Deceptive Practices Observed by the International Group and its Commercial Partners Whilst trade sanctions are applied widely by governments to promote individual foreign policy objectives, the following jurisdictions are particularly relevant in the context of controlled activities in maritime trade:  Iran  Syria  Venezuela  Democratic Republic of Korea (DPRK)  Crimea  Cuba  Belarus Cargoes traded in breach of international and national trade sanctions appear to be on the increase. Iranian oil exports, initially heavily restricted by sanctions programmes are thought to have risen from an estimated 340,000 barrels per day in following the US withdrawal from the JCPOA to an estimated 1.3 million barrels per day in March 2021. 1 Oil swap deals involving Iranian and Venezuelan oil cargoes destined for Asian markets have been widely reported in the press. 2 1 Iran Sanctions. Congressional Research Service. https://crsreports.congress.gov RS20871 2 “Under US sanctions, Iran, Venezuela strike oil export deal”. Reuters 25 September 2021 Sanctions’ activity directed at Shipping and its supporting Industries STEAMSHIP MUTUAL UNDERWRITING ASSOCIATION LIMITED Authorised by the Prudential Regulation Authority and regulated by the Financial Conduct Authority and Prudential Regulation Authority (Registered in England and Wales – Registration number 105461. PRA and FCA registration number 202548) MANAGERS: STEAMSHIP P&I MANAGEMENT LLP SPIM is an appointed representative of Steamship Insurance Management Services Limited which is authorised and regulated by the Financial Conduct Authority (Registered in England and Wales – Registration Number OC376859. FCA registration number 597046) 2 In September 2021 the United Nations Security Council Panel of Experts on DPRK published an interim report detailing widespread infringements of UN sanctions involving shipping and the DPRK. The report can be accessed by clicking here Some of the techniques used to break sanctions have been in use for several years, while others are newer and have become more prevalent in the last 18 months. All aim to minimise surveillance and detection through confusion or concealment of the identities of vessels, their cargo, geographical location, and navigational activities. Such concealment poses risks for shipowners and their commercial partners who may inadvertentl