Sanctions Compliance in Shipping: Why Marine Insurers and P&I Clubs Need the Right Lists and Right Tools
In the fast-moving world of maritime sanctions, marine insurers and P&I clubs play a critical role in safeguarding the industry against risk. But with regulators tightening expectations and sanctions regimes growing ever more complex, it is no longer enough to rely on standard compliance approaches. Two areas that stand out as particularly important are:
- Bridging the gap between the OFSI Consolidated List and the FCDO Sanctions List
- Harnessing the power of IMO-number screening for vessels
Taken together, these measures can significantly strengthen compliance defences and protect the maritime community.
The OFSI–FCDO Gap: A Hidden Risk for Maritime Stakeholders
Most firms in the UK shipping and insurance sectors are familiar with the Office of Financial Sanctions Implementation (OFSI) Consolidated List, which captures financial sanctions imposed by the UK government. However, what is less widely understood is that the Foreign, Commonwealth & Development Office (FCDO) Sanctions List includes additional designations that do not always appear on OFSI’s list.
This gap creates a real compliance blind spot. For example, a vessel might appear on the FCDO’s list under broader foreign policy measures (think Travel Bans, Trade Sanctions and Dark Fleet – things beyond just asset freezes) but be absent from the OFSI consolidated dataset. Relying solely on OFSI therefore leaves firms exposed to enforcement, reputational damage, and operational disruption.
As highlighted in Brighter Consultancy’s analysis, a robust approach means screening against both lists. For P&I clubs and marine insurers, adopting this dual-source method ensures that vessels, charters, and transactions are fully covered, reducing the risk of inadvertently engaging with sanctioned parties.
Why IMO Numbers Transform Sanctions Screening
Even with the right lists in place, screening is only as good as the data used. Traditional vessel name-based screening has long been the industry standard, but it is increasingly inadequate. Ships frequently change names and ownership structures, while fuzzy name matching creates a deluge of false positives that drain compliance resources.
This is where the International Maritime Organization (IMO) number comes in. As a unique and permanent identifier, the IMO number remains with a vessel throughout its operational life, regardless of changes in name, flag, or ownership. Screening by IMO number therefore offers:
- Elimination of false positives – No more chasing irrelevant name matches.
- 100% accuracy – A vessel’s identity is always clear.
- Operational efficiency – Compliance teams can focus on real risks.
- Regulatory defensibility – IMO-based checks demonstrate to regulators that you are applying best-in-class, risk-based processes
As Global RADAR’s IMO-powered platform shows, this approach is already being trusted by global insurers and underwriters to future-proof compliance operations.
This means greater confidence in underwriting decisions, reduced compliance overhead, and stronger protection against sanctions breaches.
Why This Matters
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:
- Protect members from hidden sanctions exposure
- Enhance operational resilience
- Demonstrate robust compliance to regulators and stakeholders
Final Thoughts
Sanctions compliance is no longer a “check-the-box” exercise, it 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.