Sanctions evasion and ship-to-ship transfer patterns

Ship-to-ship transfers are a documented mechanism for obscuring the origin or destination of cargo under sanctions. By transferring oil, grain, or other commodities at sea, outside port jurisdiction and beyond direct customs oversight, sanctioned actors insert a step in the supply chain that breaks the paper trail between producer and end buyer. The technique is not new, but its scale and geographic spread have expanded materially since 2022 in response to expanded sanctions regimes targeting Russian, Iranian, and North Korean maritime activity.

Apply STS transfer analysis when AIS data shows a vessel rendezvous pattern in open water, when a dark period coincides with a known transfer zone, or when a sanctions investigation requires documentation of cargo chain disruption. The core indicators are well-established: AIS-off periods in open water, concurrent dark periods for two vessels in proximity, flag or name changes proximate to a transfer, and commodity flow mismatches. Each indicator, individually, is ambiguous. The pattern, corroborated across sources, is not.

MAR-007 sets out the methodology for identifying, documenting, and presenting ship-to-ship transfer evidence to evidentiary standard.

Six tooling sources, five OPSEC requirements, eight workflow steps, five false-positive patterns, six chain-of-custody requirements, six key queries.

A PDF version of MAR-007 is available below for Signal subscribers.