2025 OFAC Advisory: What Maritime Compliance Must Look Like Now

OFAC’s May 2020 advisory marked a turning point. U.S. regulators formally acknowledged for the first time that sanctions evasion in the maritime domain was no longer just about sanctioned entities – it was about how those entities operated prior to any formal designation.

This advisory introduced the concept of deceptive shipping practices (DSPs) and clarified that behavioral risk was equally important as list-based risk. OFAC identified behaviors such as AIS spoofing, false flagging, complex ownership structures, and ship-to-ship (STS) transfers as red flags that may indicate illicit activity. The advisory let maritime stakeholders know they were expected to detect and address DSPs as part of their compliance responsibilities. 

Key Takeaways from the 2020 Advisory

• Behavioral focus: DSPs became critical indicators of risk, including AIS manipulation, STS transfers, and false flagging
• Expanded due diligence: in addition to behavioral focus, compliance would require monitoring ownership changes and flag histories, not just screening names
• Proactive enforcement posture: stakeholders would be expected to identify and act on patterns of evasion, even without a direct link to a sanctioned entity

This shift laid the groundwork for a more dynamic, proactive, and intelligence-led approach to compliance – one that would continue to evolve.

OFAC’s April 2025 advisory marks a decisive escalation in maritime sanctions enforcement. Building on the foundation laid in 2020, it broadens the definition of DSPs and reinforces the U.S. government’s focus on actors and behaviors enabling sanctions evasion, particularly around Iranian oil exports.  

The advisory identifies an increasingly sophisticated set of tactics, including the use of shadow fleets, falsified documentation, and front-organizations in third-party countries to mask ownership structures, all intended to obscure the origin and destination of sanctioned cargo.

What’s New in 2025

A quick review of the regulatory highlights makes it evident how much more stringent the new requirements are: 

• Expanded list of evasion tactics: highlights falsified documentation, location and identity manipulation, and STS transfers as core methods used to obscure activity and evade sanctions
• Multiple STSs trigger an in-depth investigation of all involved vessels: following successive, multiple ship-to-ship (STS) engagements, “it is essential to research all involved vessels, not only by name, but also using multiple identification and location data points.”
• Location (GNSS) manipulation is in play: it was cited for the first time in a formal advisory
• “Zombie vessels” and identity manipulation must be detected – zombie vessels (“the International Maritime Organization (IMO) number of a vessel that has been scrapped and is no longer in operation”) were mentioned for the first time. Using the IMO of scrapped entities, or the MMSI of “clean” entities is forbidden 
• Proof that vessels weren’t going dark: vessels claiming their AIS was off for legitimate reasons will need to provide documents to prove it was legit: “If a ship needs to disable its AIS in response to a legitimate safety concern, the ship should document the circumstances that necessitated disablement, and stakeholders including shipowners, charterers, ship managers, and flag registries should receive documentation as appropriate.”
• Shadow fleet identification: introduces a strong focus on Iranian-linked oil tankers operating covertly, often poorly maintained, uninsured, and active in high-risk zones
• Tighter oversight of flag registries: reinforces the importance of registering vessels under jurisdictions with rigorous compliance standards 

The new OFAC advisory significantly widens the net of the risks introduced in 2020. Enforcement is no longer limited to operators or vessel owners. It goes several steps further, focusing on the full network of actors, enablers, and systems that allow sanctions evasion to scale. 

The new advisory now includes insurers, financial institutions, brokers, and other commercial players who may unknowingly (or knowingly) support illicit behavior.

This OFAC shift signals a broader enforcement philosophy from monitoring individual red flags, to mapping how those red flags are connected across vessels, companies, registries, and financial systems. 

The 2025 advisory raises the stakes and expands the scope of who’s responsible for mitigating sanctions risk. Whether you’re managing fleets, financing shipments, insuring cargo, or overseeing port operations, the message is the same: reactive sanctions compliance is NOT enough and you are required to have a detailed picture of what is happening. Organizations need to rethink how they manage sanctions risk at every level of their operations. 

You’ll Need…

• Stronger due diligence, with visibility into vessel movements, vessel networks, flag histories, and patterns such as STS transfers and AIS manipulation
• Tighter contractual controls that address high-risk behaviors and include clear terms and defined actions for non-compliant counterparties 
• Broader operational responsibility as insurers, financial institutions, and port operators are expected to track, assess, and mitigate deceptive shipping risks across their operations
• Integrated compliance strategy, with cross-functional ownership across legal, commercial, and operations teams supported by scalable technology

Meeting the expectations of OFAC’s 2025 advisory isn’t just about receiving more data – it necessitates the ability to surface real risk, in real time, across every layer of your operations.

Windward’s Maritime AI™ platform was built for this challenge. Our solutions combine vessel behavior analytics, ownership visibility, and AI-driven alerts to help commercial and government stakeholders stay compliant, reduce exposure, and make confident decisions at scale.

Here’s how we support end-to-end sanctions risk management:

• Detect dark activity and GNSS manipulation with patented AI models trained to automatically identify suspicious behavioral patterns and hidden location tampering
• Monitor complex ownership networks using visual link analysis (VLA) to uncover indirect connections between vessels, companies, and high-risk jurisdictions
• Track multiple ship-to-ship transfers with 96% accuracy, identifying risky patterns in near real time, with insights and risk recommendations on all entities involved. 
  • This includes second vessel criteria, so traders and shippers can efficiently extract relevant data sets about who vessels of interest are engaging with
• Assess behavioral risk across entire fleets with automated scoring, proprietary risk indicators, and configurable risk profiles
• Streamline investigations and reporting with Gen AI-powered vessel insights, risk summaries, and explainable intelligence

The bottom line is that the risk of sanctions is now systemic, and regulatory pressure is only increasing. Windward gives you the technology, context, and confidence to stay ahead and compliant.