Compliance & VSCP (Vessel Sanctions Compliance Procedure)

Establishing the Gold Standard for Regulatory Transparency in Global Maritime Trade.

At SanctionedShipping.com, compliance is not a hurdle—it is our core product. We operate at the intersection of international trade and complex regulation. To protect our clients, our ship owners, and our financial partners, we maintain a rigorous Vessel Sanctions Compliance Procedure (VSCP) that meets and exceeds the standards set by OFAC, the UN Security Council, and the European Union.

The VSCP Framework: Our Five-Gate System

We utilize a multi-gate verification process for every fixture. If a voyage, vessel, or entity fails at any gate, the fixture is terminated immediately.

Gate 1: Entity Screening (KYC & KYB)

We perform "Know Your Customer" (KYC) and "Know Your Business" (KYB) checks on all parties involved in a transaction. This includes:

  • Charterers & Sub-Charterers

  • Registered Owners & Ultimate Beneficial Owners (UBO)

  • Technical & Commercial Managers

  • Banking Institutions & Payees

Gate 2: Vessel Forensic Analysis

Beyond basic IMO registration, we conduct a forensic audit of the vessel’s history:

  • AIS Integrity: We flag any vessel with a history of "dark activity" or "spoofing."

  • STS Risk: Any vessel involved in unauthorized Ship-to-Ship transfers is blacklisted.

  • Flag Registry: We monitor for "Flag Hopping" or the use of fraudulent registries.

Gate 3: Cargo & License Verification

We ensure that the cargo being moved is permitted under international law.

  • Humanitarian Carve-outs: We specialize in food, medicine, and medical devices under General Licenses.

  • Dual-Use Monitoring: We screen technical equipment to ensure it does not violate "Dual-Use" export controls.

  • Documentation Audit: We verify Bills of Lading, Certificates of Origin, and Phytosanitary certificates for absolute accuracy.

Gate 4: Financial Pathway Vetting

To ensure the "Paper Trail" is unbroken, we coordinate with compliance officers at correspondent banks to ensure that freight and hire payments are processed through transparent, non-sanctioned channels.

Gate 5: Port & Agent Due Diligence

We only engage with local port agents who have been vetted for anti-bribery and corruption (ABC) compliance under the UK Bribery Act and US FCPA.

Our Stance on the "Dark Fleet"

SanctionedShipping.com does not support, fix, or consult for the "Dark Fleet" or "Shadow Fleet." We recognize that the rise of unregulated, unvetted vessels poses a catastrophic risk to the environment and the global financial system. Our brokerage is dedicated to providing Tier-1 tonnage for complex regions, ensuring that every vessel carries valid P&I insurance from reputable International Group clubs.

Transparency with Regulators

We maintain an open-door policy regarding our methodologies. We proactively align our internal checklists with:

  • OFAC's Maritime Advisory regarding illicit shipping practices.

  • UN Security Council resolutions on maritime sanctions.

  • BIMCO’s Sanctions Clauses for Time and Voyage Charters.

Compliance as a Service (CaaS)

For organizations that are risk-averse but need to operate in high-friction zones, we offer compliance consulting. This includes:

  • Voyage Risk Assessments: A pre-fixture report on potential regulatory pitfalls.

  • Letter of Indemnity (LOI) Review: Ensuring clauses are legally robust and compliant.

  • Sanctions Clause Drafting: Tailoring charter party terms to protect your specific interests.

Reporting & Ethics

If you are a regulatory body or an insurance compliance officer seeking more information on our internal VSCP protocols, please contact our Compliance Officer directly.

Compliance Desk: Email: info@sanctionedshipping.com Attn: Chief Compliance Officer (CCO)