September 17, 2026
77 Ships Blacklisted, None Deterred: Inside Iran's Failing Hormuz Toll Regime
Know Your Vessel – Case studies in steering clear of sanctions evasion
What’s inside?
Global trade financing is an increasingly complex task for financial institutions, especially when vessels are involved. Many authorities now expect financial institutions to implement sophisticated controls when it comes to shipping. These include screening and monitoring for potential sanctions violations, trade-based money laundering, and other high-risk transactions.
Recently, the U.S. Office of Foreign Assets Control (OFAC) put out a new advisory describing common deceptive shipping practices. It also recommends a list of due diligence procedures for organizations across the maritime ecosystem to implement.
Given the large volume of transactions and the need for timely processing of transactions, it is not feasible to complete Enhanced Due Diligence (EDD) on every transaction. Financial institutions must rely on a risk-based approach to protect themselves and keep their business on track.
Know Your Vessel: Case Studies in Steering Clear of Sanctions Evasion examines two public examples where standard screening tools failed to identify red flags associated with a vessel involved in a transaction and reviews the resulting risks to the transaction parties.
It goes on to explain how a Know Your Vessel (KYV) process such as considering the vessels’ prior behavior would have flagged the transaction. It ends by describing how KYV can be incorporated into the transaction screening process.
Featured posts
77 Ships Blacklisted, None Deterred: Inside Iran’s Failing Hormuz Toll Regime
At a Glance Operational Overview Iran’s Persian Gulf Strait Authority opened in mid-May to oversee transits and toll payments through the Strait of Hormuz. It has since released three tranches of blacklisted vessel names, on August 24, September 2, and September 14. Windward analysis of all 77 vessels finds that every one used the “unauthorized”…
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The Houthis Take Perim and Petroline Is Hit as Freight Rates Cross $1 Million a Day
At a Glance Operational Overview Saudi Arabia’s workaround to the partial closure of the Strait of Hormuz came under direct attack last week. Saudi Arabia diverted crude to the Red Sea port of Yanbu via the East-West pipeline. On September 10, a pumping station on the pipeline was attacked and preemptively shut down. On the…
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Subsea Cable Surveys Are Converging on the Same Behavioral Signature
At a Glance Four Vessels Worked Five Pacific Cable Systems Simultaneously Four Chinese state-owned research vessels conducted surveys directly above five Pacific cable systems this summer. Pacific Light Cable Network, Hawaiki, Bulikula, Honotua, and Juno. Each shows the same behavioral profile of sustained low speed, grid tracklines, and multi-day dwell in position, consistent with systematic…
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What Marine Underwriters Are Now Pricing Against
At a Glance Underwriting Is a Pricing Decision Made on Incomplete Data Underwriters carry the pricing decision at two moments in the coverage process. At binding, the underwriter takes compliance’s assessment of the vessel and its operating context, applies actuarial models and loss history, and sets premium and terms. At renewal, the underwriter takes the…
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Your Sanctions Audit Trail Has to Survive a Ten-Year Lookback
At a Glance OFAC Doubled the Retention Period in 2025 On March 12, 2025, OFAC’s extended recordkeeping requirement took effect, doubling the retention period for records of transactions subject to its regulations from five years to ten. The final rule followed an interim rule published in September 2024 and adopted it without change. The driver…
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Panama Canal Restrictions Are Landing on an Already Broken Chokepoint Map
At a Glance The Canal Is Cutting Capacity in the Wrong Season The Panama Canal Authority will run nine daily slots at the Neopanamax locks and 25 at the Panamax locks from September 4, averaging 34 transits per day. That falls again on September 15, when the limit drops to 32 ships. The canal had…
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