A Regulatory Necessity & 4 Steps for Navigating 2024’s Sanctions Reality

Risk & Compliance

What’s inside?

    Part 1 and 2 of this blog post series hopefully caught you up to speed on the historical sanctions shift and the 4 key factors affecting the sanctions balance. The landscape of maritime trade has transitioned from a relatively static environment, to a dynamic web of evolving regulations and emerging risks.

    Are You Ready for the Price Cap Update?  

    Speaking of evolving regulations, the G7 price cap coalition published an update on the price cap rules and they went into effect this week on February 19 for cargos loaded on or after February 20

    If cargo is transferred via ship-to-ship (STS) transfer, it is a requirement that a per-voyage attestation is provided within 30 days of the STS meeting occurring. But organizations that cannot detect relevant STS engagements will have no way of knowing that they need a new attestation! This has become a necessity…

    Windward’s risk evaluation is enhanced through data it pulls from our ship-to-ship model, because STS engagements are often important indicators for various deceptive shipping practices (DSPs), such as oil smuggling. 

    Windward offers the only solution in the industry that provides a dynamic, AI-driven STS model, with a 96% accuracy rate of flagging illicit STS. The model goes beyond proximity to determine that cargo was transferred, Additionally, our suspicious cargo module can help determine the origins and metrics for suspicious cargo. 

    The ability to differentiate between cargo and servicing/bunkering operations will help organizations clearly define when attestations are required in a more detailed way, saving time and money. 

    Additionally, the EU approved a 13th package of sanctions against Russia yesterday, banning nearly 200 entities and individuals accused of helping Moscow procure weapons, or for being involved in kidnapping Ukrainian children. 

    Navigating the New Reality

    To thrive in the complex and ever-changing regulatory and sanctions environment, businesses must embrace the following four steps/approaches:

    • Proactive Compliance Culture: cultivating a culture of compliance within the organisation, through comprehensive training programs and robust internal control mechanisms, is essential for mitigating risk and upholding ethical standards.
    • Strategic Partnerships: building strong relationships with regulatory bodies, financial institutions, and industry peers facilitates information sharing, best practice development, and collaborative risk mitigation efforts.
    • Investment in Expertise: equipping personnel with the necessary knowledge and skills in areas like sanctions compliance, trade finance, and maritime security empowers them to make informed decisions and navigate complex situations effectively.
    • Technological Acumen: leveraging technology – such as AI STS models, data analytics and AI-powered monitoring tools – can significantly enhance due diligence efforts and detect potential red flags with greater accuracy and efficiency.

    Constant evaluation and learning have become crucial prerequisites for safe and secure trade in 2024 and beyond, especially considering the complexity around Russia sanctions – with the EU extending them for six more months – as well as the sanctions against Yemen’s Houthi rebel group. 

    By embracing constant evaluation and learning, and utilising the most advanced technologies, businesses can navigate this increasingly demanding environment with confidence, ensuring the safety and security of their operations and their reputation in the long term. 

    Simon Ring
    Windward Senior Director – Trade & Shipping Technologies

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