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February 13, 2021

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The Certified Anti-Money Laundering Specialist (CAMS) credential is the gold standard in AML certifications and recognized internationally by financial institutions, governments and regulators as a serious commitment to protecting the financial system against money laundering.

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Drive a culture of compliance from the top down by building highly skilled teams staffed with subject matter experts Demonstrate to regulators and examiners their dedication to a standardized risk-based approach for protecting against money laundering threats and financial crime risks Meet mandated AML training requirements through preparation and study and satisfy ongoing training through recertification and advanced certification activities Safeguard more effectively against financial and reputational damage

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Financial Action Task Force
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solving Sanctions Compliance and Due Diligence in Maritime alternate | CAMS cheat sheet and boot camp

windward The Iranian product tanker Fortune arrives in Venezuela with a sanctioned cargo, may additionally 2020 (file photo courtesy FANB)

by way of Ami Daniel 02-17-2021 06:37:00

After a rocky 2020, the world trade landscape is rarely shaping as much as be a clean one in 2021.

In 2020, the office of international belongings control (OFAC) in the U.S. posted its maritime compliance advisory in may additionally and the workplace of economic Sanctions Implementation (OFSI) within the UK followed go well with in June with its own maritime advisory. each advisories require all corporations within the maritime ecosystem to screen for vessel behaviors, and never simply the vessel itself. however, it's now increasingly clear that primary blacklist screening methods for customer due diligence now not suffice.

because of these advisories and different regulations in 2020, they noticed 58 vessels and 35 shipping-related agencies blacklisted. however maritime stakeholders shouldn’t simplest be specializing in who is being sanctioned, however additionally why and where. whereas each of these acts of sanction can also were acceptable on their own phrases, considered within the combination, the crackdown is raising critical questions in relation to the skill to alternate with self belief. Given this dynamic, a brand new means of drawing near compliance, anti-money laundering (AML), and financial crime is required.

In a contemporary conversation with David Peyman, a former State branch reputable who created the department’s first financial sanctions concentrated on crew, he drove home simply how profoundly the sanctions panorama has shifted. From a regulatory standpoint, Peyman advised me, the maritime sector today is where the banking sector changed into before the introduction of AML and anti-secrecy legal guidelines, implying they will assume regulatory changes to be able to force actors to increase their compliance controls and due diligence procedures. The decent information is that there are tools – including these in response to AI – that allow these actors to no longer fall in the back of the ball.  

With a brand new U.S. administration, now is the time to take a step back to keep in mind what they are seeing related to sanctions and AML, and to chart the applicable approach for 2021.

now not black and white

based on Rick McDonell, government Director of the affiliation of certified Anti-money Laundering experts (ACAMS), “The digitization of economic features has tremendously improved entry and comfort for everybody, however it’s additionally opened the doors for more chance, diversity and complexity in terms of economic crime. For fiscal institutions and regulators, making certain that compliance departments and officers are appropriately informed to become aware of fiscal crime, and empowered actually to do anything about it, is paramount.” 

currently, we’ve considered probably the most largest AML cases ever in Hong Kong, which joins an IMF investigation in the Nordics and Baltics.

but with the brand new U.S. administration signaling their intention to reopen diplomatic negotiations with Iran, the outlook for sanctions is a sophisticated one. the days of black and white are over, and they are all left navigating a constant mixture of shades of grey. It gained’t be best about whether that you could or can’t alternate with a undeniable country. There could be a becoming variety of restrictions and provisions so as to take compliance professionals an expanding period of time to navigate as they are looking for to make certain their agencies reside out of harm’s way.

The shipping business’s exciting challenges

On the shipping and buying and selling aspect, the new compliance necessities enacted by the U.S. (OFAC) and the uk (OFSI) make it more and more problematic for the regular compliance skilled.

no longer most effective do AML, fiscal crime, and compliance gurus at banks and power businesses should navigate ever-changing regulations and dissimilar primary databases, now they additionally need to develop into experts within the complex maritime business. Underscoring the scope of the challenge, fresh experiences point out that there are diverse situations of vessels registered in different Pacific islands as a method to keep away from sanctions – a phenomenon that used to most effective exist in the legislations enforcement area, instead of being important for common compliance and shipping gurus. 

In January 2021 on my own they witnessed a surge of maritime linked sanctions:

For the first time ever, after many warnings, we’ve viewed a vessel and a company blacklisted with the aid of the U.S. over their involvement within the Russian-backed Nord circulation 2 pipeline mission. The vessel Fortuna – a pipelaying vessel – may be simply the first warning, with many insurers and banks refusing to do company with entities involved in this venture. The blacklisting comes as the US-Russia relationship faces new turbulence within the wake of the Solarwinds hack, and the heightening of geopolitical tensions all but guarantees that the Nord movement problem is not going to be resolved each time soon. in response to Windward records, the currently sanctioned Fortuna pipelaying service vessel has used three ports in Germany as a base of operations for the German Landfall of the Nord flow 2 mission. When cross-referencing this with the Russian port aiding this operation they see 16 different vessels working in both ends of the assignment during the past six months. moreover, eleven entertaining vessels have been aiding the Fortuna directly during the past six months and conducting distinct STS operations, best 4 of which are Russian flagged. in line with the remarks of each insurers and economic institutions involving the due diligence manner, these vessels and their respective businesses may discover themselves exposed.

The U.S. Treasury centered six vessels and three organizations buying and selling with Venezuelan oil, including Swissoil (primarily based in Geneva) and Elemento (based in Malta). If they center of attention on Fides Ship management LLC, all 4 of its now sanctioned vessels have changed flags to Cameroon in 2020. Two of the tankers carried out what's described by means of OFAC as “Flag Hopping” – repeatedly registering with new flag states. The flags of alternative are not dazzling as the registry manner is fairly handy with the registries now not being thoroughly aware about what is being done beneath their flag.

Cuba has been positioned on the U.S. blacklist recently, in a step that may still no longer alternate a good deal considering it has lengthy been an advanced nation to behavior company with. in accordance with Windward’s insights, there are nevertheless approximately 330 vessels with a excessive risk of designation for Cuba-linked actions. however even for entities which have up to now been trading in Cuba there is a 30% reduce in port calls in Cuba during this fall 2020, probably as a result of the blacklisting via the Trump Administration.

The U.S. Commerce branch has put China’s CNOOC on its “entity record,” meaning that U.S. corporations may be unable to export items or technology to the enterprise in the absence of a hard-to-gain license. however the Entity checklist (EL) offers with export manage and is very diverse from the peculiarly particular Nationals (SDN) list, it nonetheless requires a different permit which is not likely to be offered, with the new trend in U.S. banks' AML and financial crime due diligence techniques to query inquiries to or from EL entities. This complexity is even better due to the fact the company's tankers perform numerous STS operations with a world fleet including pretty much 50 vessels owned and managed outdoor China. besides the fact that children the publicity is distinctive than with SDN record entities, vessels and groups interacting with the CNOOC fleet in Southern China could locate themselves uncovered.

Time for a distinct strategy         

With so many evolving risks, and so many people talking in regards to the indisputable fact that facts is the new oil, it’s time to trust a different method – one that harnesses the power of facts to pressure enhanced business choices.

At a time when even screening of the typical shipping business’s “Seven degrees of possession” has develop into a sophisticated task, AI structures can supply a bottom-line advice with clear explanations and an audit path. They should empower compliance, AML, and monetary crime professionals to include really expert AI techniques that leverage domain potential, presenting them with bottom-line techniques. These suggestions – on the vessel, company, and cargo tiers – can also be absolutely built-in into current IT programs and allow for client Due Diligence (CDD) and deep investigations.

With really good AI systems, buying and selling with confidence in 2021 and beyond doesn’t must be complicated.

through Ami Daniel is the CEO & Co-founder of Windward.

The opinions expressed herein are the author's and never always these of The Maritime executive.

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