In the world of maritime sanctions, marine insurers and P&I clubs play a vital role in protecting the sector from regulatory and operational risk. But as expectations from regulators increase and sanctions regimes grow more intricate, relying on standard compliance approaches is no longer enough.
Two areas are particularly critical for effective sanctions risk management:
Used together, these enhancements can significantly strengthen compliance defences and reduce risk exposure for the maritime community.
Most UK-based shipping and insurance firms are familiar with the Office of Financial Sanctions Implementation (OFSI) Consolidated List, which includes individuals and entities subject to asset freezes. However, fewer firms are actively screening against the Foreign, Commonwealth & Development Office (FCDO) Sanctions List, which captures a broader set of designations.
This includes:
This omission creates a compliance blind spot. A vessel may be sanctioned under the FCDO’s wider measures and still go undetected if a firm screens solely against OFSI.
As highlighted by Brighter Consultancy’s recent analysis, best practice means screening against both lists. For P&I clubs and marine insurers, adopting this dual-source approach significantly reduces the risk of unintentionally engaging with sanctioned parties - whether through underwriting, chartering, or claims handling.
Even with the right lists in place, screening is only as effective as the data behind it.
Traditionally, most compliance tools rely on vessel name-based screening. But ship names and ownership structures change frequently, and fuzzy name-matching techniques often produce large numbers of false positives. This clogs up resources and creates unnecessary investigative burden.
Enter the IMO number.
Assigned by the International Maritime Organization, this unique vessel identifier remains with a ship for its entire life, regardless of changes in:
Using IMO numbers for sanctions screening offers:
Sanctions breaches carry not only financial penalties but also reputational damage that can ripple through the maritime insurance ecosystem. Marine insurers and P&I clubs that equip themselves with both comprehensive sanctions list coverage (OFSI + FCDO) and precision screening via IMO numbers will be best placed to:
Sanctions compliance is a strategic imperative.
By addressing the OFSI-FCDO gap and shifting from name-based to IMO-based screening, you can take a proactive stance in safeguarding yourselves, your members and the wider maritime sector.
Need help reviewing or upgrading your sanctions controls? Contact Brighter Consultancy for independent expertise and practical support.