1 OFAC advised that tactics used to facilitate sanctionable or illicit maritime trade also serve as indicators that actors may be evading the price cap. Such tactics include: disabling or manipulating the automatic identification system (AIS) on vessels; physically altering vessel identification; falsifying cargo and vessel documents; ship-to-ship (STS) transfers; voyage irregularities; false flags and flag hopping; and complex ownership or management. The U.S. Departments of State and Treasury, and the U.S. Coast Guard issued a global advisory on May 14, 2020 discussing these red flags and best practices in further detail.
2 OFAC advised that whether the use of a shipping route or transshipment point for shipping seaborne Russian oil is abnormal can be determined by past practice or historic AIS data, a lack of historic AIS data for a particular tanker or fleet of tankers owned by a particular shipper, transshipment through one or more jurisdictions for no apparent economic reason, and sudden unexplained changes in route.