Economic sanctions: practical due diligence for new shippers

Entering a shipping trade means checking more than freight rates and vessel availability. Sanctions exposure can arise through counterparties, ownership interests, cargo origin, destination, services and payment arrangements. The relevant rules depend on the jurisdictions and persons involved; being new to the industry does not itself create an exemption.

The US Treasury’s Office of Foreign Assets Control issued a maritime advisory in April 2025 concerning Iranian petroleum-related sanctions risks. It addresses a wide range of participants, including owners, managers, operators, insurers, ports and financial institutions. It is an existing advisory, not evidence of a new regulation aimed specifically at new shippers on 16 March 2026.

The advisory highlights deceptive shipping practices and encourages risk-based diligence. Reviewing vessel identity, ownership and management information, voyage history and cargo documentation can help identify inconsistencies that need investigation. An apparent gap in tracking information or an unusual transfer is a reason to examine the facts; it is not, by itself, a finding of a sanctions breach.

Screening should not stop with a vessel name. IMO identification helps distinguish ships with similar or changing names, while ownership and control checks address risks that a simple name search can miss. Counterparties, intermediaries and payment participants also require consideration under the applicable regime. A negative list result is not a universal assurance that a transaction is lawful.

Contract terms and the commercial workflow should support the checks. Parties can define what documentation is required, who may request clarification and what happens if a compliance concern remains unresolved. Screening records should show the sources consulted and the timing of checks, with further review when a party, voyage or applicable rule changes.

For a new shipper, a workable process combines current official guidance, reliable identity information, documented decisions and specialist advice where needed. Commercial permission to transit a waterway should not be mistaken for an exemption from sanctions. This article is a compliance overview, not legal advice, and does not allege misconduct by any vessel shown or company mentioned.