Screening a vessel for sanctions means checking the ship, the companies behind it and its recent behaviour before you quote, deliver or pay. The May 2020 sanctions advisory from OFAC, the US State Department and the US Coast Guard expects a wide range of maritime businesses, including ship chandlers, brokers, insurers and port operators, to run risk based checks of this kind. Here is a practical way to do it.
1. Start with the IMO number
Names change; the seven digit IMO number stays with the hull. Confirm it from the RFQ, the agent or the vessel's documents, and use it for every check that follows.
2. Check the vessel against sanctions lists
Screen the IMO number and vessel name against the lists that apply to your business, such as the US OFAC lists, the EU's list of vessels under port access bans, the UK list and UN lists. The EU alone had listed 342 vessels by its 17th package in May 2025, and lists change often, so check every time rather than relying on a past result.
3. Look through to the owners and managers
Identify the registered owner, the commercial manager and the technical manager, and screen each one. Single ship companies in secrecy jurisdictions with no operating history deserve a closer look.
4. Review flag and name history
Frequent changes of flag or name, or a recent move to a flag with weak oversight, are classic signs of a dark fleet vessel.
5. Check recent behaviour at sea
Look at the tracking record for AIS gaps and for ship to ship transfers in open water, especially near high risk areas. Ask the operator to explain anything unusual.
6. Record the decision
Keep a record of what you checked, what you found and why you went ahead or declined. If a regulator or a bank asks later, a documented decision is your best evidence of a working compliance process.
Which sanctions lists matter in shipping
Which lists apply to you depends on where your company is based, the currency you are paid in, and the requirements of your banks and insurers. Payments in US dollars, for example, can bring US sanctions into play even for companies outside the US. The lists most maritime businesses check are:
- US OFAC Specially Designated Nationals (SDN) List. Names people and companies, and identifies sanctioned vessels by IMO number.
- EU sanctions. Including the EU list of vessels banned from EU ports and from EU maritime services.
- The UK Sanctions List. The UK's own designations, which do not always match the EU or US.
- The UN Security Council Consolidated List. Measures adopted by the UN Security Council.
When to screen
- When an RFQ arrives, before you spend time quoting
- Again before delivery, if days or weeks have passed since the quote
- Before you accept payment, and check who is paying
- Whenever the vessel changes name, flag, owner or manager
Red flags at a glance
| Signal | Why it matters | What to do |
|---|
| AIS gap near a known transfer area | Can hide a port call or a cargo transfer | Ask the operator for the log entry and the reason |
| Recent change of name or flag | A common way to break the link with past activity | Screen every previous name and check the IMO number |
| Single ship owner in a secrecy jurisdiction | Hides who really controls the vessel | Identify the managers and screen them too |
| Ship to ship transfer in open water | Can disguise where cargo came from | Screen the other vessel and the transfer location |
| No recognised P&I insurance | Often seen with dark fleet tankers | Ask for the certificate of entry |
| Payment from an unrelated third party | Can hide the real buyer | Confirm who is paying and why |
What to do if you find a possible match
Stop before you quote, deliver or accept payment. Confirm whether it is really the same vessel by checking the IMO number, not the name. Escalate to whoever handles compliance in your business, and take legal advice where the position is unclear. Do not go ahead until the match is cleared, and record what you found and what you decided. This guide is general information, not legal advice.
Common mistakes
- Screening the vessel name instead of the IMO number
- Screening once when a customer is set up, and never again
- Checking only the ship you supply, not the other ship in a ship to ship transfer
- Screening the vessel but not its owners and managers
- Making the right decision but keeping no record of it
How Tidal helps
Tidal screens vessels and counterparties against sanctions and watchlists, checks beneficial ownership and the IMO number, pulls together compliance history such as port state control and detention records, and documents every decision. See maritime sanctions screening software for how to choose a tool.
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