What Defensible Marine Insurance Compliance Looks Like in 2026

At a Glance

• Compliance managers touch four of the five stages of the marine insurance coverage process, from underwriting through ongoing monitoring, claims support, and renewal.
• The operating environment has changed structurally in 2026, with GPS jamming compromising AIS reliability, sanctions activity outpacing screening tools, and false flag operations growing to include Syria and Myanmar as newly emerged fraudulent registries.
• Static, one-time checks based on declared flag and registered owner are no longer sufficient, given that 62% of tankers active in the Iran trade are falsely flagged and 87% are sanctioned.
• Ongoing monitoring is where the workload has grown most, as sanctions designations continue at high volume, dark activity surged sevenfold quarter-over-quarter, and behavioral risk indicators shift faster than annual review cycles can capture.
• The insurance certificate itself has become a piece of evidence in the sanctions enforcement environment, with legitimate insurers now needing to prove their coverage is clean rather than simply claim it.
• All-source intelligence combining AIS with satellite imagery, radio frequency detection, ownership tracing, and behavioral history provides the sensor-verified vessel activity that supports defensible compliance decisions across every stage.

Compliance Sits at the Center of the Coverage Process

Compliance managers in marine insurance carry a heavier operational load in 2026 than at any point in the recent past. The coverage process has five stages: new business enquiry, underwriting, ongoing monitoring, claims, and renewal. Compliance touches four of them, more than any other function in the workflow.

At new business intake, compliance runs initial screening on ownership and sanctions exposure, giving the underwriter the go or no-go input needed to move a new client through to pricing. During the policy period, compliance runs continuous monitoring, watching for any change in the counterparty’s exposure profile. At claims, compliance supplies the evidence base that determines whether the vessel was engaged in sanctionable activity at the time of loss. At renewal, compliance surfaces the full term’s monitoring history that informs whether the policy is renewed, repriced, or declined.

Compliance’s specific responsibilities vary by insurer, but the function is consistently present across four of the five stages of the coverage process. Everywhere except policy issuance, compliance is what determines whether the insurer’s risk picture is accurate and defensible.

In 2026, that risk picture has become materially harder to build.

What Has Changed

Three shifts define the environment compliance managers now work in.

AIS Is Not Reliable In The Regions Where Insurance Exposure Concentrates

Windward tracked 171,286 vessels affected by GPS jamming at least once globally in Q2 2026. Since Operation Epic Fury began on February 28, 2026, 3.35 million false ship-to-ship meetings have been recorded, in which injected positioning coordinates made vessels appear to rendezvous when no meeting took place. Jamming is persistent in the Middle East Gulf, the Black Sea, the Mediterranean, and other high-exposure regions. For a compliance manager screening vessels operating in these regions, the AIS-based voyage history that underpins screening decisions carries embedded uncertainty. A vessel may show a clean port call history because its actual sanctioned calls were concealed behind jammed coordinates.

Sanctions Activity Is Outpacing Screening Tools

Regulators worldwide made 486 vessel designations in Q2 2026, on top of 851 in Q1. The EU 21st sanctions package adopted on July 23, 2026, introduced 218 new listings and expanded designation criteria to cover vessels providing services to shadow fleet ships for the first time, including bunkering. The OFAC-OFSI Comparative Overview published on June 23, 2026, formally documents the differences between U.S. and UK sanctions frameworks. Compliance managers operating across multiple regimes need to structure screening to satisfy the more demanding standard in each dimension.

Declared Identity Often Is Not Actual Identity

Q2 2026 saw 275 tankers broadcasting fraudulent registry flags, with 22 fraudulent ship registries now identified. Russia-linked tankers falsely claimed the flags of Syria and Myanmar during Q2 for the first time. Around 90% of tankers using fraudulent registries are Western-sanctioned. Of approximately 430 tankers currently active in the Iran trade, 62% are falsely flagged, and 87% are sanctioned. Static screening based on declared flag captures none of this.

These are the operational conditions across every stage compliance manages. 

Screening

At new business intake, compliance runs the initial screening that determines whether a prospect moves through to underwriting or gets flagged for further investigation. The workload at this stage has grown for several reasons.

Sanctions list screening now needs to be paired with fraudulent registry checks, since a vessel passing a sanctions list check under its declared flag may be operating under an unauthorized fraudulent flag that conceals its actual identity. Ownership tracing has become more intensive as single-ship special purpose vehicles, opaque registered ownership chains, and Russia-incorporated management entities are increasingly used to defeat beneficial ownership screening. The EU 21st package’s coverage of service-providing vessels adds a new screening dimension. Compliance screening a bunker tanker now needs to assess not only the vessel itself but the vessels it services. Providing bunkering to a shadow fleet vessel can bring the bunker vessel within sanctions scope, regardless of whether the shadow fleet vessel is individually designated.

For an underwriter waiting on the compliance assessment before pricing and binding, the analytical output needs to reflect all of this. Static reports based on declared vessel identity alone are no longer adequate.

Ongoing Monitoring

Ongoing monitoring is where the workload has grown most.

Dark activity surged sevenfold quarter-over-quarter, with 3,137 prolonged dark activity events recorded in Q2 2026 involving 2,157 unique vessels. Russian waters and ports concentrated nearly 4,000 individual events. Every prolonged dark period is a window during which the vessel’s activity was not self-reported. A vessel that goes dark during the life of a policy may return to visible AIS with a materially different risk profile than what the policy was originally underwritten against.

Sanctions designations continue to arrive at high volume, and each one requires the compliance team to check whether any currently insured vessel is affected. The 21st EU package’s 218 new listings all need to be run against the active portfolio. So do subsequent OFAC and UK designations, which have been arriving in rolling waves throughout 2026.

Behavioral pattern shifts also require ongoing detection. The behaviors that most reliably surface hidden exposure include ship-to-ship transfers in unusual locations, sudden changes in trading pattern such as a first visit to a new port, and uneconomical routing where a vessel’s movement, dwell time, or extra distance carries no legitimate commercial justification given its stated cargo and destination. For a compliance manager monitoring a vessel with a policy in force that begins exhibiting any of these patterns, the exposure change is not visible in AIS position alone. It is visible in the behavioral pattern.

Claims

At claims, compliance supplies the evidence base for whether the vessel was engaged in sanctionable or non-compliant activity at the time of loss. The claims team runs the loss investigation and owns the pay-or-reject decision. Compliance’s answer determines whether that decision holds up.

Reconstructing what a vessel actually did in the period before, during, or after a loss event often requires investigation that AIS alone cannot always support. Consider a common current-environment scenario: a vessel operating in the Middle East Gulf during Q2 2026 sustains loss. The AIS record for the period preceding the loss shows the vessel operating in areas of GPS jamming, with position data that may include injected coordinates. The vessel also spent portions of the period dark. The claims team asks compliance whether the vessel was engaged in sanctioned activity at the time of loss. Compliance’s answer depends on reconstruction from sources beyond AIS.

The Court of Appeal ruling in Tonzip Maritime v 2 Rivers Pte Ltd (“The Catalan Sea”) handed down on May 22, 2026, clarified that the threshold for invoking sanctions clauses in charterparties is a reasonable judgment of a real risk of sanctions, not proof that a breach would probably occur. The case does not directly address insurance claims but signals how courts are calibrating the evidential threshold for sanctions-related decisions in the current environment.

For compliance supplying evidence at claims, this raises the standard for defensibility. A claims decision based on AIS position alone in a jamming-affected region may be vulnerable to challenge. A claims decision based on multi-sensor reconstruction that verifies actual vessel activity is materially more defensible.

Renewal

At renewal, compliance surfaces the full monitoring history from the term that just ended, and underwriting reassesses whether to renew, reprice, or decline.

The quality of the reassessment depends on what compliance monitored during the term and what the monitoring surfaced. A vessel that showed clean AIS throughout the term but exhibited behavioral pattern shifts worth flagging looks different at renewal than a vessel with an unremarkable operating history. A vessel that entered jamming-affected regions during the term and returned with reconstructed activity that supports the underwriting picture looks different from a vessel with unexplained dark periods.

Sanctions regulations apply as soon as they take effect, not at renewal. But the renewal is where the term’s accumulated regulatory shift, the EU 21st package, the OFAC-OFSI comparative framework, fraudulent registry growth, and operational realities, flows into the vessel or fleet reassessment. The renewal quote is where all of this either shapes the next term’s pricing or does not.

How Windward Supports Compliance Managers

Windward’s Maritime AI™ Platform supports compliance across the four stages it touches.

At screening, Know Your Vessel (KYV™) supports the go or no-go assessment compliance needs to make on a new prospect. Ownership tracing, flag history, behavioral patterns across multiple voyages, and identity changes are aggregated into a single operational view that identifies whether a vessel is fit to move through to underwriting or requires further investigation. Behavioral risk profiling surfaces the operating patterns that mark shadow fleet activity, sanctions evasion behavior, or vessels providing services to designated ships.

During the policy period, continuous screening runs across the full lifecycle. Sanctions list updates, new designations, and behavioral pattern shifts are surfaced in near real time. When a vessel conducts a ship-to-ship transfer in an unusual location, makes a first visit to a new port that departs from its historical trading pattern, or exhibits uneconomical routing that carries no legitimate commercial justification, the compliance team is notified.

At claims, All-Source Operational Intelligence supports the forensic reconstruction that investigations increasingly require. All-source intelligence, as the Department of Defense defines it, incorporates all sources of information in the production of finished intelligence. Applied to marine insurance claims, that means AIS combined with SAR and EO imagery, RF detection, ownership records, sanctions data, behavioral history, and any additional sources the reconstruction requires. The output is a defensible evidence base for whether the vessel was engaged in sanctioned or non-compliant activity at the time of loss.

At renewal, the accumulated monitoring history provides the analytical foundation for the reassessment.

The presence of a vessel in a GPS jamming-affected area is not, by itself, a behavioral risk indicator. GPS jamming is something happening to a geographic area, not something a vessel is doing. Vessel risk is assessed independently based on behavioral patterns and operating history.

Where This Leaves Compliance

The compliance workload for marine insurance in 2026 is not returning to the prior baseline. Structurally changed AIS reliability, sustained sanctions pressure, growing false flag operations — this is now the baseline.

Compliance managers who have adapted their screening, monitoring, claims support, and renewal processes to reflect this environment are tracking and managing portfolio risk exposure and preventing exposure to hidden risk. Compliance managers still running the workflow they ran three years ago are supporting insurers whose risk pictures increasingly do not match what is actually happening across the fleet they are covering.

The gap between the two is measurable in enforcement exposure, claims defensibility, and portfolio quality across the renewal cycle. It will continue to widen.

Written by Maya Romi, Windward Maritime Intelligence Content Specialist. Reviewed by Angela Freeth, Product Marketing Manager, Commercial.