STS (Ship-to-Ship Transfer) Red Flags

Indicators that a ship-to-ship cargo transfer is being used to evade sanctions. OFAC’s 14 May 2020 maritime advisory flagged STS conducted at night or in areas not normally used for such operations, transfers preceded by AIS disabling or manipulation, mismatched cargo documents, and transfers near sanctioned jurisdictions such as off Iran, Syria, or the DPRK. The DPRK regime bans STS with North Korea-flagged vessels outright under UNSC Resolution 2375 (2017). Legitimate STS follows MARPOL Annex I Chapter 8 procedures and an approved plan.