In the second case, a more complicated layering process is involved. This is called the Indirect Vessel Identity Laundering Operation and once again involves a ‘dirty’ vessel. The first step is to commercially obtain an existing ‘clean’ vessel. This vessel undergoes extensive modifications designed to hide its true identity and the perpetrators then claim, much as in the first case, that the existing ‘clean’ vessel, is actually a new build and not the original vessel. The ‘new build’ now has all remnants of its original identity removed…and sails away as the ’new build’ with a new identity, including a new digital identity. The ‘dirty’ vessel, through further modifications designed to mimic the former commercially acquired ‘clean’ vessel, now acquires the digital and physical identity of the original ‘clean’ ship…and also sails away with what is in truth… a new identity.
CHANGING THE IMO NUMBER OF ‘DIRTY’ VESSELS… AND MAKING THEM APPEAR ‘CLEAN’!
The one key point here, that has until recent times stopped such Vessel Identity Fraud from happening, has been each vessel’s unique IMO number. Despite any changes of ownership, flag registration and even name, the original IMO number has always been unique to each vessel throughout its lifetime. This gave ‘…a level of legitimacy that enables a vessel to access regulatory and financial services it needs to operate safely and engage in commercial activity…’ according to the C4ADS report. Well…the North Koreans…and maybe others…have found a way of getting a new IMO number to ‘dirty’ vessels…and making them appear ‘clean’.
The risk to shipping lies not just in this identity fraud and its cargoes…but in what the consequences are for all the maritime industry. Financial institutions including banks and other financing institutions, insurers, shipping companies and anyone involved in maritime trade have received guidance and warnings from OFAC (U.S. Office of Foreign Assets Control) and OFSI (U.K. Office of Financial Sanctions Implementation). However, at the centre of this has been how the IMO handles its issuance of IMO numbers and also how various shipping registers manage their lists of vessels.
9 | ADMISI - The Ghost In The Machine | Q4 Edition 2021
A possible solution that has been put forward is the IMO require resubmission of vessel photographs and details of current operators at regular intervals which would be a mandatory requirement for a vessel to maintain its IMO number registration. Additionally, to publish and make known vessels that have been taken off the IMO numbering system. The IMO has said it is reviewing its ship registration system.
As you can see, this type of fraud is now getting more sophisticated. AIS tampering has become a common tactic used by those wishing to hide the identity of vessels. This Vessel Identity Fraud is the next level in the constant fight against such perpetrators. I now wonder…what will become the next level after this one?
Eddie Tofpik E:
eddie.tofpik@
admisi.com T: +44(0) 20 7716 8201
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