Quint-Seal Compliance Note: Know Your Cargo 22 January 2024 No.23-021 Tweet Download PDF (282KB) On 11 December 2023, five US agencies (the Department of Justice, Commerce Department’s Bureau of Industry and Security, Department of Homeland Security’s Homeland Security Investigations, State Department’s Directorate of Defense Trade Controls, and Treasury Department’s Office of Foreign Assets Control) released a joint compliance note “ Know Your Cargo ” (the “Compliance Note”), highlighting tactics commonly deployed by malign actors in the transportation sector and best practices for the maritime and other transportation industries as well as examples of enforcement actions.   The Compliance Note provides guidance for all companies in the maritime sector—vessel owners, charterers, exporters, managers, brokers, shipping companies, freight forwarders, commodities traders and financial institutions, including (re)insurers.   Best Practices The Compliance Note builds further on previous guidance from OFAC relating to sanctions evasion in the maritime industry, including the Sanctions Advisory for the Maritime Industry published on 14 May 2020 and the Advisory for the Maritime Oil Industry published on 12 October 2023.   Itreiterates best practices including: Develop, implement, and adhere to written, risk-based operational compliance policies, procedures, standards of conduct, and safeguards; Conduct risk-based due diligence on the location history of vessels or vehicles, to identify prior manipulation or disabling of location or identification tracking data; Implement robust know your customer due diligence; Exercise of risk-based supply chain due diligence to verify “the true nature, origin, and destination of the cargo they are involved in transporting”; Share information across industries and supply chains, as appropriate.   Red Flags The Compliance Note identifies several red flags that may indicate attempts to evade sanctions and export controls