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The U.S. government has seized an oil tanker for involvement in
ship-to-ship (STS) cargo transfers with a sanctioned vessel and
other sanctions evading activity. The vessel Courageous (IMO:
8617524), owned and operated by a Singaporean citizen, stopped
transmitting its AIS (Automatic Identification System) location
signal between August and December 2019. During this period, the
Courageous transferred oil cargo worth $1.5m to the North Korean
flagged vessel Saebyol (IMO:8916293). Saebyol eventually discharged
her cargo at the port of Nampo, North Korea.
In the period leading up to the STS cargo transfer, the movement
activity of the Courageous placed it at the port of Kaohsiung
throughout 2019. She idled in the anchorage of the Taiwanese port
for considerable periods of time both before and after the STS with
the Saebyol. After her prolonged period of not transmitting an AIS
signal, the Courageous reemerged back on the radar in February 2020
at Kaohsiung and departed for Cambodia. On reaching the port of
Kompong Som, in Cambodia in March, the vessel was held by Cambodian
authorities and subsequently seized by the U.S.
As part of the STS operation with the Saebyol, the Courageous
was also noted to have falsely identified itself as another vessel.
She has previously operated under the name Sea Prima with the flag
of St Kitts and Nevis.
The pattern of activity by the Courageous closely resembles that
of another vessel, the Wise Honest, seized by the U.S. in 2019. The
two vessels have a similar movement pattern used to evade sanctions
ranging from AIS dark outages, STS cargo transfers and falsifying
cargo documentation with which to transmit payments through the
U.S. financial system. This latest seizure of the Courageous
underlines the key sanctions evasion techniques highlighted in the
Office of Foreign Assets Control (OFAC) advisory of May 2020 on
'Guidance to Address Illicit Shipping and Sanctions Evasion
Practices'. The United Nations Security Council has also
imposed economic sanctions on North Korea, prohibiting among other
things the conduct of ship-to-ship transfers with DPRK-flagged
vessels and the provision of petroleum products to North Korea.
Within the OFAC advisory a series of deceptive shipping
practices were highlighted as operational recommendations for
sanctions compliance teams to be aware of and to incorporate into
their daily maritime screening processes. There is a strong
correlation between OFAC's general practices for identifying
shipping risk and the evasion of sanctions by the Courageous.
The core OFAC recommendations are:
Disabling or Manipulating a Ship's AIS Signal:
The Courageous had minimal coverage under AIS, when its AIS was
transmitting there was very little port call history, suggesting a
vessel not fully engaged in normal shipping practices
Flag Hopping and Flag Changes: In 2019-2020,
the Courageous changed flags on three separate occasions, flags of
convenience were used in all cases
Vessel Name Changes: Between 2016 and 2019 a
series of name changes to the vessel also occurred - Blue Sea, Sea
Prima and finally Courageous
Age of the Ship: Older vessels have been
identified as being more likely to be engaged with illegal maritime
activity. The Courageous was built in 1987
Ownership and Management: Four different
corporate entity changes occurred within the ownership structure of
the Courageous between 2017-2020
Additionally, the vessel had no port state control inspection
since 2004 and had been 'disclassed' by the Nippon Kaiji Kyokai
ship classification society in 2011. While flags of convenience,
vessel name or ownership changes do not always constitute red
flags, when taken as a whole with a pattern of AIS outages, no hull
inspection activity and prolonged periods of idling, the risk level
increases for that ship.
For trade compliance teams to protect themselves, they must
ensure they include in their toolbox the key lessons from the
seizure of the Courageous and understand the types of activity such
vessels engage in order to avoid transactional risk.
