Red Flag (Sanctions)

An indicator that a transaction, vessel, or counterparty may involve sanctions evasion, prompting closer review. OFAC’s 14 May 2020 maritime advisory listed the maritime set: AIS gaps or manipulation, ship-to-ship transfers in unusual locations, voyages with no clear economic logic, falsified cargo or vessel documents, frequent flag-hopping, and opaque or recently changed ownership. A red flag is a prompt for enhanced due diligence, not proof of breach; clearing it requires documentation, not assumption.