The vessel nobody actually screened.
A tanker is due alongside for bunkers and stores. The agent has confirmed the nomination. The supplier has the provisions list ready. The bunker barge is fixed, and a surveyor has been booked to attend the delivery. Four separate companies, four separate service agreements, and by the time the vessel sails, it is entirely possible that not one of them has actually screened it, because each one assumed somebody earlier in the chain already had.
Named Everywhere, Owned Nowhere
OFAC's (the U.S. Treasury's Office of Foreign Assets Control) sanctions guidance for the maritime industry reads, at first glance, like it covers everyone: owners, managers, operators, brokers, ship suppliers, flag registries, port operators, shipping companies, freight forwarders, classification societies, insurers, and financial institutions are all named as parties expected to exercise due diligence. That breadth is the point of the guidance. It is also exactly why the check so often does not happen. When a responsibility is assigned to everyone in a long list, it tends to default to no one in particular, because each named party has a plausible reason to believe the check already happened somewhere upstream.
How the Assumption Actually Travels Down the Chain
The agent confirms the nomination on the strength of owner’s, manager’s or charterer’s reputation. They might have done vetting in the past, long time ago. The agent then instructs the local parties needed to execute that call, the supplier, the surveyor, and some of them receive the job through the agent rather than directly from the vessel's owner. Receiving an instruction through an established, trusted agent reads as a form of vetting in itself, even though it is not one. The agent was never screening on the local parties' behalf, and the local parties were never screening the vessel on their own account. Everyone in the chain did their job. Nobody actually ran the check on the day that mattered.
What Each Party Can Control, Without Relying on Anyone Else
The fix is not a new committee or a compliance function. It is each party treating their own point of contact with the vessel as the moment their own check happens, rather than a moment someone else's check already covered.
- Agents: past checks do not cover a vessel or company detail that changed, or a re-flagging, or recent risky behavior. Screen again at the point of confirming the nomination.
- Suppliers: a job arriving through a trusted agent is a routing decision, not a screening result. Screen the company and vessel independently before extending credit or scheduling delivery.
- Service providers (pilotage or launch services, surveyors, launch operators, and similar): the same logic applies. Being instructed by an agent is not confirmation that the underlying vessel or company has been checked. A quick screen before attending the job takes the same few minutes as checking a berth schedule.
The Same Check, Whichever End of the Chain You Sit At
Whatever the role, the check itself does not change: screen the vessel and the company by IMO number against the major published sanctions lists, look at the name and flag history for a pattern of frequent change, and note whether the registered address sits in a risky jurisdiction. None of that requires coordinating with the other three companies involved in the call. It requires not treating their involvement as a substitute for your own.
Making It Fast Enough That Nobody Has an Excuse to Skip It
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Whichever end of the port call chain you sit at, run your own check rather than counting on someone else's. Sign-up for a Maritime Intelligence Free Trial, or run a Free Sanctions Check on the vessel or company in front of you today.
