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As regulators continue to clamp down within the sanctions space,
it's becoming apparent how historically some players would try to
circumvent traditional screening methods in order to continue
operating under the radar… or under AIS in this case. The release
of the May advisory by OFAC surrounding "Guidance to address illicit
shipping and sanctions evasion practises" perfectly
encapsulates methods such as AIS tampering and falsified vessel
information/documentation, and the necessity for having robust
systems in place to carry out in-depth investigations on vessels
and their owners.
Through the long years in which IHS Markit has been issuing and
maintaining the IMO registry for vessels and companies, our data
specialists have had to develop an increasing level of awareness to
identify suspected false applications. The IMO number is very much
like a vehicle identification number (VIN) or your own thumb print,
unique and unchangeable for the duration of its lifespan. As such,
vessels that are - or have historically been - 'tagged' as having
breached sanctions or recorded undertaking suspicious activity may
be inclined to try and apply for a new IMO number under false
pretence to effectively receive a new identity.
The Application:
Such an account was recently captured by one of our specialists,
whereby a potentially false application was submitted. The
application was deemed "suspicious" due to inconsistencies in the
provided information, including discrepancies between flag, call
sign/maritime mobile service identity (MMSI), the company name, and
the class details. The application was also submitted on a Sunday;
why is this significant? Sunday might be a non-working day in many
parts of the world, but in other parts, this is the equivalent to a
Monday.
The flag of register provided was claimed to be the "Northern
Mariana Islands", a US commonwealth in the Pacific Ocean, but the
call sign given on the form started with "V7", which is allocated
to the Marshall Islands. The Maritime Mobile Service Identity
[MMSI] number started with 536, which doesn't fit with the range
for the US Northern Mariana Islands when checked on the
International Telecommunication Union [ITU]. The classification
society given was DNV GL, and that it was supposedly classed
between 2009 and 2014 (cannot be found on their register), with a
built date of 2013.
But it doesn't stop there, as an IMO registration form requires
an abundance of additional data points before submitting, such as
the Gross Tonnage (158,921), the length (333) the breadth (60), the
number of main engines (2) and more - these technical descriptions
aren't atypical for a Very Large Crude Carrier (VLCC), but the fact
that this vessel has been in existence for several years and
suddenly registers for an IMO number is very unusual, particularly
when you refer back to the IMO registration scheme.
The Review
Our market-leading ship vetting tool, the Maritime Intelligence
Risk Suite (MIRS) was used to conduct several checks to see if the
MMSI and vessel name have existed historically. According to MIRS
Ship database, there is no current ship, nor has there been one
historically, named as such, nor is there any record of the MMSI
pertaining to a registered vessel. If one however looked on the AIS
tracking tool, to see if any ship is transmitting as that name or
MMSI, they would have found at the time, a solitary ship in the
Gulf of Guinea matching in name, flag, Call Sign and MMSI, as well
as having similar width, length.
Looking at the vessels track over the last 365 days reveals that
it was only first seen on the 17th of September at 09:46:03 UTC
within the Gulf of Guinea (24 days before the IMO application came
through), where at the time it was in close proximity to, and
possibly calling at the Bonny Inshore/Offshore terminals within
Nigeria (which happened to be its destination at the time), only to
then sail south down the western coast of Africa with a destination
of Qingdao, China, and a draught of 20.2 meters.
Figure 1: Vessel of interest as seen historically on AIS
When inconsistencies such as this arise, it becomes difficult to
discern the truth from fiction, particularly in instances like
these where the build of the vessel appears sound, but no trace of
it can be found under the IMO registry… which begs the question,
could this in fact be a vessel already in existence under the IMO,
trying to gain a new identity?
If one was to look at the MIRS database for tankers with a
length of >300, breadth of >60, a DWT of >290,000, GT of
>150000, the system outputs 104 Vessels to have been built to
such a standard. Of the 104 vessels, 15% of these have a Severe
Compliance status, indicating that there is a high risk associated
with these vessels (37% have a warning, and 48% are OK). Regardless
of however which way you filter and segment this fleet, no singular
vessel comes forth covering all provided technical specifications.
If however we remove all of the vessels which have been seen in the
last 30 days from when this vessel appeared on AIS, this leaves us
with 11 vessels (using 30 days as it takes 30 days to travel from
Middle East Gulf to Gulf of Guinea at 10kts; most of these vessels
were last seen in the Gulf/South East Asia).
Overall summary of 11 vessels:
10/11 are Iranian Flagged
5/11 match the year of build
2/11 match the builder
10/11 have sanctioned owners
10/11 are OFAC sanctioned
2/11 match the country of build
6/11 match the given length
11/11 match the given breadth
This is of course speculation, and by no means conclusive; but
vessels in such a position would revel in having a new IMO number
that would allow them to sail unhindered under a new identity.
IHS Markit has a 250-year heritage as the industry's
authoritative source of shipping information. We manage the largest
maritime ships database in the world, evolved from The Lloyd's
Register of Ships, which has been continuously published since
1764. In addition, the firm is an industry leader in validating
maritime data and setting standards for vessel descriptions. The
IMO, for example, has nominated IHS Markit - Maritime & Trade
as the sole authority for managing its unique ship identifiers. We
have since been referenced by several regulators, including the OFAC May Advisory, UN Security Council August Report.
