In an article published on 31 May 2021 on how shipping has had to respect sanctions compliance over the past year, it is reported that the Office of Foreign Assets Control (OFAC), the US State Department and the US Coastguard sanctions advisory makes it clear that "the onus of responsibility for sanctions compliance lies with everyone across the supply chain, and stressed the need for the private sector to plug the many holes currently used to circumvent sanctions". 

The supply chain includes ship-owners, operators, managers, charterers, brokers, flags, ports, shippers, freight forwarders, commodity traders, insurers, and financial institutions. 

It is fundamental that organisations have policies and processes in place to comply with sanctions. Apart from the ability to investigate issues, organisations also need to demonstrate and evidence how this is operationally achieved. Hence, the adoption of technologies is essential to obtain a full picture of a vessel’s activities.

Ince has launched an enhanced specialist sanctions compliance solution through a co-operation agreement with Windward, the Predictive Intelligence company applying AI to transform global maritime trade. This new proposition will enable charterers, insurers, owners, investors, brokers, ship operators, financial institutions and defence agencies to benefit from a smarter, faster and forward-looking approach to risk mitigation. Ince's collaboration is supported with New York based law firm, Seward & Kissel LLP, to enable clients to obtain sanctions legal advice covering the EU, England & Wales and U.S. sanctions applications, together with the new best risk analysis and reporting tools available, all under one roof. 

The collaboration marks the development of another managed service solution for InceMaritime, the first being cyber security in co-operation with Mission Secure launched in February 2021.

Please note this article was written by Annette Fong, who is no longer with Ince. If you would like any advice in this regard, please contact Julia Dao.