The UK has joined the US in instructing the shipping industry on ways to avoid its sanctions regime, but officials struck a much different tone than their American counterparts.
On Monday, the UK's Office of Financial Sanctions Implementation (OFSI) released a 12-page document outlining issues shipping companies should be on the lookout for — from potential illicit shipping practices to countries under UK sanctions to due diligence expectations.
It stands in contrast to the 35-page US guidance released in mid-May that provides sector-by-sector expectations for the industry.
"The US sanctions advisory really was about prescribing certain things companies across the industry should be doing to limit their sanctions risk," said K2 Intelligence FIN vice president Eric Lorber.
"This guidance read much more like an educational document. It's much more focused on, generally speaking, the types of obligations you have and the things you should be concerned about."
The OFSI used its guidance to walk readers through practices that could be used by entities busting sanctions, like turning AIS off, ship-to-ship transfers or false documentation.
It also provided a brief on UK sanctions and defines what authorities mean by control and ownership, as sanctions block business dealings with individuals or entities controlled by those on the blacklist.
But the OFSI broke with the US guidance in its less-aggressive tone.
For AIS, the UK noted that there are legitimate reasons for a ship to turn off its transponder, while the US takes a harder stance on its use, arguing it should be on at all times.
Despite the "gentle touch", Lorber said the OFSI appeared to take a more US-style enforcement strategy as it transitions out of the European Union.
The OFSI has been willing to take public enforcement actions toward businesses outside shipping.
It also suggested the UK is focusing on shipping the way the US has in recent years.
"I do think that the UK is focused on sanctions enforcement more than any other jurisdiction other than the US," Lorber said.
"And they're focused on the maritime sector as a locus of that sanctions enforcement. I do think that there is clearly a signal here that companies operating in the space should be concerned and up their compliance game."
