The U.S. Treasury’s Office of Foreign Assets Control (OFAC) issued a new maritime sanctions advisory on April 16, 2025, that signals a pivotal shift in compliance expectations. The update doesn’t just revisit the deceptive shipping practices (DSPs) introduced in 2020, it expands the scope of what regulators consider red-flag behavior, particularly in connection with Iranian oil experts and shadow fleet activity.
For maritime stakeholders, the message is clear: compliance now demands a Know Your Vessel™ approach – continuous, behavior-based vessel risk assessments that go far beyond static lists. It’s worth noting that unlike our competitors, Windward is a KYV pioneer and has even trademarked the term.
The Foundation: 2020 and the Rise of Behavioral Risk
OFAC’s May 2020 advisory marked a turning point in maritime compliance. For the first time, regulators formally recognized that sanctions evasion wasn’t just about who was on the list, but also how entities behaved.
Rather than relying solely on sanctioned party screening, stakeholders were expected to detect and respond to deceptive shipping practices such as:
- AIS spoofing
- Flag hopping
- Complex ownership structures
- Ship-to-ship (STS) transfers
The takeaway? Risk couldn’t be assessed from a static snapshot. It required a dynamic understanding of vessel behavior, affiliations, and movements over time.
The Evolution: 2025 and the Expanding Risk Landscape
Fast forward five years, and OFAC’s April 2025 advisory made it clear that sanctions risk is now systemic. The advisory broadened the scope of deceptive shipping practices and introduced new layers of scrutiny, including:
- Shadow fleets operating under obscure ownership and poor safety standards
- Falsified documentation and identity manipulation
- Location (GNSS) manipulation (location tampering) cited for the first time in a formal advisory
- Zombie vessels, which are ships operating under recycled IMO numbers of scrapped vessels
- A demand for proof for vessels claiming legitimate AIS disablement
- Multiple STS transfers now warrant a full investigation, not just of the primary vessel, but of every entity involved
Mitigating this level of risk requires full behavioral visibility and the ability to connect the dots across vessels, fleets, and ownership networks.
This is where Know Your Vessel™ becomes not just helpful, but essential.
What Does It Mean to Truly Know Your Vessel™?
In today’s enforcement landscape, reactive compliance is no longer enough. Vetting a vessel once, or just checking it against a list, won’t protect you from the operational and reputational risks that come with maritime trade.
At Windward, Know Your Vessel™ (KYV™) isn’t a buzzword – it’s a trademarked framework for operationalizing maritime due diligence. It goes beyond static screenings to deliver dynamic, real-time risk assessments across behavior, ownership, cargo, and connections.
It’s not just about who owns the vessel, but also how that vessel behaves, who it’s linked to, and whether its activity puts your organization at risk.
KYV™ empowers stakeholders across trade, finance, energy, and government to vet vessels with confidence, using the full picture of ownership and behavioral risk.
Windward’s KYV™ includes:
- Dynamic vessel risk scores powered by proprietary AI models
- Ownership and flag history tracking, including flag-hopping
- Deceptive behavior detection, like dark activity, loitering, and STS transfers
- Network analysis of affiliations with high-risk jurisdictions
- Behavioral risk patterns that update in real time
- Visual Link Analysis (VLA) to uncover hidden ownership and shell structures
Whether you’re a trader clearing a deal, a regulator assessing exposure, or a port authority vetting a vessel for entry, KYV™ ensures you have the full context before making a move.
This isn’t traditional screening. It’s compliance intelligence, built for the complexity of today’s global trade.
Navigate Evolving Sanctions Risk with KYV™
OFAC’s 2025 advisory reinforces that compliance is no longer a one-time check. Every vessel engagement now demands ongoing scrutiny, because risk isn’t static. Shadow fleets evolve, identities shift, and a once-vetted vessel can take on new red flags overnight.
That’s why Windward’s Know Your Vessel™ solution was built for this exact moment.
We move beyond static screenings to deliver intelligence-led, real-time vessel vetting. KYV™ continuously monitors risk, flags changes in behavior, and supports fast investigations with Gen AI-powered summaries, so you can stay ahead of emerging threats without drowning in data.
The result?
Better decisions. Faster response. Fewer compliance surprises.
The future of maritime compliance is proactive, dynamic, and behavioral. You need to Know Your Vessel™, and Windward can help!
Ready to See KYV™ in Action?
