On December 11, 2023, the U.S. Departments of Commerce, State, Justice, Treasury and Homeland Security published a joint Quint-Seal Compliance Note, “Know Your Cargo: Reinforcing Best Practices to Ensure the Safe and Compliant Transport of Goods in Maritime and Other Forms of Transportation.”

The agencies highlight the increasingly complex nature of global supply chains and opportunities for nefarious actors to evade export control laws and U.S. sanctions. The note also highlights the responsibility of individuals and entities participating in the global transport of goods to assess their risk profile and implement compliance programs.

Potential Indicators of Efforts to Evade Sanctions and Export Controls

The note directs companies involved in funding and facilitating the transport of cargo to be aware of these practices that may suggest export control or sanctions evasion: 

• Manipulating location or identification data
• Falsifying cargo and vessel documents
• Ship-to-ship transfers
• Voyage irregularities and use of abnormal shipping routes
• Frequent registration changes” that evade national provisions; and
• Complex ownership or management

Recommended Compliance Practices

The note recommends that individuals and entities who participate in maritime and other transportation industries should implement and strengthen compliance controls as necessary, especially when operating in high-risk areas or when dealing with entities who demonstrate suspicious behavior. A non-exhaustive list of compliance practices includes:

• Institutionalizing sanctions and export control programs
• Establish location monitoring best practices and contractual requirements
• Know your customer
• Exercise supply chain due diligence
• Industry information sharing

The note also encourages individuals and companies to report suspicious behavior to the relevant U.S. authorities.

Recent Activity to Combat the […]