Unsurprisingly the authorities in the US and elsewhere have warned businesses involved in shipping to be aware of evasion attempts. In April, OFAC specifically singled out P&I clubs, ship owners, flag registries, and commodities brokers to remain vigilant for deceptive shipping practices as evidence of sanctions evasion. Bomgardner said that while some service providers such as P&I clubs and flag registries had sprung up just to support the Dark Fleet some vessels posing a high risk continued to be served by reputable organisations.
There are complications. Dark Fleet vessels are not used exclusively for sanctioned trade – and not all vessels present the same level of risk. For instance, they may be shipping oil within the confines of the price cap. However, they do present an increased risk to those in the bunker business. The advice is to be careful when dealing with a Dark Fleet vessel and conduct enhanced due diligence on the provenance of the cargo, the buyer and the seller.
That is where companies like Pole Star come in. They can undertake checks that enable businesses to discharge their due diligence responsibilities. Given current geopolitics their services are likely to be needed for the foreseeable future.
However, Bomgardner concluded by saying that the risks of bunkering companies falling foul of sanctions enforcement could be reduced by using electronic documentation, as in electronic bunker delivery notes. As that is indeed the direction of travel in the bunker sector, perhaps there is some reason to be optimistic.