Sanctions circumvention at sea

Identifying a sanctioned vessel is far from plain sailing, writes Bobby Hussain

In 2025, the US and UK governments each expanded their respective sanctions regimes to target vessels linked to Russia’s ‘shadow fleet’, a surreptitious fleet of vessels Russia uses to transport oil to finance its ongoing invasion of Ukraine.

This expansion of the US and UK regimes, which named specific boats, froze assets and blocked financial flows, was a bold one. But within weeks, several of the listed vessels had vanished from tracking systems, were reflagged or renamed, or had had their ownership obscured through offshore structures.

The US and UK attempt to draw Russia’s clandestine fleet from the shadows, and the Russian response, demonstrates why name-based vessel sanctions create a regulatory blind spot, allowing ships to evade sanctions, reappear under new identities and continue their activities.

Sanctioning a vessel is only half the battle. Without transparency in asset ownership, enforcement is merely symbolic. Whether targeting Russian oil tankers or smuggling skiffs, regulators are hitting the hull but missing the companies controlling the vessels. It is these companies which will apply for finance, obtain funding against the vessel and pay crew members. The real risk for financial institutions is, therefore, the legal entities behind the vessels; the challenge lies in tracing control, not just naming assets.

Sanctioning a vessel is only half the battle. Without transparency in asset ownership, enforcement is merely symbolic.

A fragile enforcement architecture

Both the US and UK regimes allow for the designation of vessels linked to sanctioned actors. These designations trigger asset freezes, port bans and service restrictions. But in practice, enforcement often hinges on the vessel’s name rather than its IMO number, ownership structure or operational control.

This creates a fragile architecture: ships can be renamed, reflagged or obscured through offshore entities, while the underlying control remains untouched.

The case studies that follow illustrate how sanctioned vessels can slip through regulatory cracks, not because they physically disappear, but because their identity fragments across registries and jurisdictions. Before we consider how this takes place, we need to recognise the different means by which a vessel can be identified.

• IMO number. A unique seven-digit identifier assigned by the International Maritime Organization (IMO) to every sea-going vessel. Unlike ship names or flags, the IMO number remains constant throughout a vessel’s life, even if the ship is renamed, reflagged or sold. It’s the most reliable anchor for tracking a vessel across registries and sanctions lists.
• Ship name. The vessel’s commercial name, which can be changed at any time by the owner.
• Flag state. The country under whose laws the vessel is registered and whose flag it flies. Some jurisdictions often lack transparency and are overrepresented in sanctions evasion cases.
• Registered owner/legal owner. The legal entity listed as the owner in maritime registries. The legal entity can be registered in a low-transparency jurisdiction and may not reflect the true controller or beneficiary of the vessel.
• Operator/ISM manager. The company responsible for the vessel’s day-to-day operations and safety management. Operators may be distinct from owners and can be used to mask control. Sanctions regimes differ on whether operators constitute ‘control’ for designation purposes.
• Beneficial owner. The individual or entity that ultimately owns or controls the vessel. Even if not listed as the legal owner, the beneficial owner is difficult to identify without open and transparent registries.

The mechanics of ownership concealment

Sanctioning a vessel is one thing, but tracing who owns and controls it is another, as information related to ownership and control is often buried in registries and the information itself shot through with layers of legal and corporate obfuscation. The following are among some of the means of obscuring ownership and control.

• Shell companies. Incorporated in low-transparency jurisdictions, often with no operations or staff.
• Nominee directors and shareholders. Used to mask the true controller, often family members or close associates.
• Discretionary trusts. These offer a separate legal title from beneficial interest, making ownership ambiguous and hard to challenge.
• Bearer shares and offshore SPVs. Enable the anonymous transfer of ownership without a paper trail.

None of these structures are inherently illegal, but they are routinely exploited to evade sanctions, delay asset tracing, frustrate enforcement actions and maintain control while avoiding visibility.

Naturally, this makes life difficult for those seeking to enforce a regime. Beneficial ownership registers are incomplete or legally shielded and maritime registries often lack transparency or coordination. Moreover, Automatic Identification System (AIS) tracking can be spoofed or disabled and any legal recovery requires cross-border cooperation and forensic intelligence.

Identifiers like the IMO number, name, flag and ownership form the regulatory scaffolding for vessel sanctions. But when they’re manipulated or obscured, enforcement falters. The following case studies show how sanctioned vessels can slip through the cracks – not because the vessels are invisible, but because their identity is fragmented.

Sanctioning a vessel is one thing, but tracing who owns and controls it is another.

Case studies

Most ships will have an IMO number, a ship name, a ship flag and an owner, operator or ISM manager. Many of the ships captured under these sanctions are registered in countries with opaque ownership structures such as Gabon, Mali, etc.

They are then also owned by legal companies in countries which also have opaque ownership rules, thus creating a distinction between where the vessel is registered and where the owner is incorporated.

Case study 1: Alissa to Soufia 1

Sanctioned name: Alissa

Crude oil tanker the Alissa was sanctioned 10 January 2025 by OFAC and sanctioned by the UK on 9 May 2025 under vessel registration identification number: IMO 9273052. At the time the vessel was flying under the flag of Gabon and its registered owner was Doxa Shipping Line Inc.

The Office of Foreign Assets Control (OFAC) recognised this and included the owner’s name (Doxa Shipping Line Inc) in the Alissa sanction. The UK, on the other hand, linked it to the ship operators Leora Shipping LLC. Both Doxa Shipping Line Inc and Leora Shipping LLC are incorporated in the UAE.

However, a quick search on Equasis – the Electronic Quality Shipping Information System – yields no results for the Alissa. However, confusingly, a search for its IMO number brings up a ship called the Soufia 1 flying under a Mali flag (indicated as being false). Looking at the history of the ship, it shows that a name change occurred 1 July 2025.

OFAC status: anyone searching the sanctions lists or automating their sanctions will only find the Alissa and will not make the link to the Soufia 1 unless they undertake additional investigation.

However, if one searched for the owner on OFAC, Doxa Shipping Line Inc, one would find this in its own right, without reference to the Alissa or the Soufia 1. The Alissa is listed but not the new name of the Soufia 1 on its own.

‘Leora shipping LL’ searched on OFAC returns zero results.

UK status: the Alissa is found under sanctions but not the new name of the Soufia 1 or the new flag. One can search for the IMO number IMO 9273052, but this links to the old name of the Alissa and not the new name of the Soufia 1.

In addition, Leora Shipping LLC is listed as the current owner operator but no reference is made to the actual owners, Doxa Shipping Line Inc. Leora Shipping and Doxa are searchable but produce many results, including the Alissa.

Impact: at time of writing, both UK and US sanction lists have only the name of the Alissa listed matching the IMO number. Financial institutions dealing with the Soufia 1 could complete any financing because the Soufia 1 is not listed on any sanction list, thus inadvertently dealing with a sanctioned entity. The IMO number and the ownership of the ship have not changed.

Case study 2: Afkada to Lindor

Sanctioned name: Afkada

The Afkada was also sanctioned by the UK and US, but a search on Equasis reveals no match. However, a search on the IMO 9311531 number reveals a ship called the Lindor flying under the flag of the Gambia. Equasis reveals this ship changed its name to the Reinel on 1 June 2025 and then again on 1 August 2025 to Lindor.

Since 2022, it has changed its flag from St Kitts and Nevis to Gabon to Unknown to Malawi (false) and now to the Gambia.

The ISM manager is Tech Marine Services and the registered owner is Viman Maritime Inc. Tech Marine is registered in India and Viman Maritime Inc is registered in the Seychelles.

OFAC status: a search for the Afkada, Reinel and Lindor produced zero results. Additional searches of Tech Marine and Viman also furnished nothing.

UK status: a search on the UK register revealed a sanctioned vessel name of Afkada sailing under the flag of Gabon with an owner operator of Qatif Maritime Inc. One can search for the IMO number 9311531 and it will show the previous name of Afkada, not the new name of Lindor. The UK sanctions designation lists Qatif Maritime Inc as the owner and this can be searched. However, the current owner is Viman Maritime Inc.

Impact: here is another regulatory gap exposed, one between UK sanctions and OFAC sanctions where there are sanctioned vessels on one list and not on the other. This makes life difficult for those institutions seeking to do business, especially those operating in cross-border financial institutions.

Case study 3: Attica to Yi Meng Shan

Sanctioned name: Attica

A search for Attica on Equasis also reveals no match. A search for IMO 9436941 reveals a ship called Yi Meng Shan which changed its name 1 November 2024. Since 2024, it has sailed under Djibouti which was later claimed to be false, and then under Comoros which was also declared false. The registered owner and ship owner is Elgon Maritime Corp registered in the Seychelles and the ISM Manager is Jun Zi Lan Shipmanagement registered in China.

OFAC status: OFAC shows the vessel listed under the old name of Attica and linked to Elgon Maritime Corporation. Elgon is separately listed but with no link to the Attica or Yi Meng Shan.

UK status: under the UK, the vessel is listed under the old name Attica and is linked Elgon Maritime Corporation. The old name of Attica can be found by searching the IMO 9436941. Searching for Elgon only shows the Attica listing and no results for Jun Zi Lan Shipmanagement.

Impact: the US and UK placed sanctions on the Attica in 2025. At the time of its designation, it was already sailing under a completely different name, the Yi Meng Shan. The sanction listing of the Attica is therefore utterly wrong and further illustrates the danger of sanctioning the name of a vessel when other data indicators are available. Sanctioning a vessel under a previous name is a critical failure.

What can be done?

The Alissa, the Afkada and the Attica each evidence different risks. To cover these, there must be action from regulators, and additional steps taken by those operating in this field.

To move from symbolic enforcement to strategic interdiction, regulators must build interoperable frameworks that link vessel identity to ownership, control and operational history.

• Utilise different data indicators and mandate IMO-linked beneficial ownership registers across flag states. This would include using IMO numbers of vessels, flags, previous and new names, ISM managers and legal owners.
• Identify beneficial owners. Whilst this would represent the Holy Grail, the legal owners of vessels are incorporated in jurisdictions in which it is difficult to find beneficial ownership information. Where it is available and corroborated, it should be used.
• Regular integrity audits for sanctioned vessels. This would require, at a minimum, quarterly checks on ships on the sanctions list to check for any changes.
• Harmonisation across regulators. Vessel designation protocols between the OFAC and UK regimes to ensure the same vessels are covered and any loopholes closed, in line with the above utilisation of different data indicators.

Regulators should be seeking to make amendments to make these steps easier. But any firm subject to the UK Money Laundering Regulations should complete their own investigations and not rely on screening against names and lists, especially in the context of vessel sanctions. As we have seen, it is relatively simple to change the name of a ship in order to evade sanctions. Multiple searches and investigations need to occur on different data points to confirm that a vessel is not sanctioned, including searching against the IMO number, the legal owners, its operators and any beneficial owners.

Any failure to do so will leave financial institutions lost at sea.

To move from symbolic enforcement to strategic interdiction, regulators must build interoperable frameworks that link vessel identity to ownership, control and operational history.