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.
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01
Required Tools
Six platforms covering AIS, SAR, sanctions screening, and STS zone monitoring.
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02
OPSEC
Legal exposure and premature disclosure risks in active sanctions investigations.
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03
Workflow
Eight-step sequence from AIS gap identification to sanctions documentation.
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04
False Positives
Five lawful operations that produce STS transfer indicators.
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05
Chain of Custody
Six requirements for documenting transfer evidence and satellite corroboration.
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06
Key Queries
Six queries across AIS platforms, OFAC SDN, and STS zone databases.
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