Screen counterparties, vessel owners and beneficial owners against applicable sanctions lists before fixing a cargo.
Oil, Gas & Energy
Sanctions Due Diligence for Seaborne Crude Oil and Refined Product Cargoes
Build sanctions due diligence for crude oil and product cargoes, tracing vessel history, ownership and AIS behaviour to screen counterparties and comply with price cap and flag state rules.
🗓️Duration5 training days
📚Content4 modules · 8 sessions
🎓On completionAccredited attendance certificate
About the programme
Course Overview
A single cargo of crude oil or refined product can pass through several owners, flags and ship-to-ship transfers before it reaches a refinery, and any one of those steps can expose a trading company to a sanctions breach it never intended. This course examines how sanctions due diligence is actually performed on seaborne cargoes: screening counterparties and vessel owners against sanctions lists, tracing AIS tracking history for gaps, spoofing or dark fleet behaviour, and verifying that a cargo's documented origin and ownership chain match its physical voyage. Participants work through the price cap compliance mechanisms that apply to Russian-origin crude and products, including attestation and shipping document requirements, and the ship-to-ship transfer patterns associated with sanctions evasion. Sessions also cover flag state and insurance due diligence, letters of indemnity risk, and how a compliance function should escalate a cargo that raises red flags partway through a voyage. Teaching uses vessel tracking case exercises, document review practice and a red-flag escalation simulation. Participants finish able to design a sanctions due diligence workflow for cargo trading, recognise the indicators of evasion, and make defensible decisions under time pressure.
Expected Learning Outcomes
Trace AIS tracking history to identify gaps, spoofing or dark fleet behaviour associated with sanctions evasion.
Verify that a cargo's documented origin and ownership chain match its physical voyage and loading history.
Apply price cap attestation and documentation requirements to Russian-origin crude and refined product cargoes.
Assess ship-to-ship transfer patterns for indicators of cargo blending intended to disguise origin.
Conduct flag state, insurance and protection and indemnity due diligence before accepting a vessel for a cargo.
Escalate a cargo that raises sanctions red flags partway through a voyage through a defensible decision process.
Who Should Attend
Compliance officers and sanctions analysts screening counterparties and cargoes for oil and product trading desks.
Chartering and operations staff who fix vessels and review voyage documentation for crude and product cargoes.
Trade finance and documentary credit staff verifying shipping documents before releasing payment.
Legal and risk teams advising trading companies on sanctions exposure in seaborne oil transactions.
Shipbrokers and vessel vetting specialists assessing vessel history before recommending a charter.
Bank and insurer staff conducting sanctions due diligence on oil trade finance and marine insurance transactions.
Course Modules
Select any module to see its sessions and points.
01Sanctions Regimes and the Cargo Trading Chain
2 sessions · 8 points
Session 1How Sanctions Regimes Apply to Oil Trading
- Compare the scope and enforcement approach of the main sanctions regimes affecting seaborne oil and product trades.
- Identify how the Specially Designated Nationals list and equivalent lists are used to screen counterparties.
- Explain how the price cap coalition mechanism restricts services to Russian-origin crude and product cargoes.
- Map the points in a cargo's life, from loading to discharge, where sanctions exposure most commonly arises.
Session 2Counterparty and Vessel Screening
- Conduct know-your-customer screening on counterparties, including beneficial ownership behind trading entities.
- Screen vessel owners, managers and flag states against sanctions lists before accepting a nomination.
- Identify red flags in counterparty structures, such as recently changed ownership or opaque beneficial owners.
- Document screening decisions so they can be defended to regulators or correspondent banks later.
02Vessel Tracking and Voyage Verification
2 sessions · 8 points
Session 1Reading AIS and Voyage History
- Interpret AIS tracking data to reconstruct a vessel's voyage history and identify unexplained gaps.
- Recognise AIS spoofing and manipulation patterns associated with disguising a vessel's true position.
- Identify ship-to-ship transfer locations and patterns commonly associated with sanctions evasion.
- Cross-check AIS history against port call records and cargo documentation for consistency.
Session 2Verifying Cargo Origin and Documentation
- Review bills of lading, certificates of origin and quality certificates for consistency with the claimed voyage.
- Trace a cargo's ownership chain from loading to discharge to identify undisclosed intermediate transfers.
- Identify blending patterns that could disguise the origin of a sanctioned or price-capped cargo.
- Assess letter of indemnity requests for red flags that suggest missing or falsified original documentation.
03Price Cap Compliance and Insurance Due Diligence
2 sessions · 8 points
Session 1Price Cap Attestation and Documentation
- Apply price cap attestation requirements when chartering vessels or arranging services for Russian-origin cargoes.
- Verify that a cargo's sale price and supporting documentation are consistent with price cap compliance claims.
- Identify the service providers, including insurers and flag states, whose participation signals price cap compliance.
- Recognise the consequences of accepting a cargo where price cap documentation appears incomplete or inconsistent.
Session 2Insurance and Flag State Due Diligence
- Verify that a vessel carries valid protection and indemnity cover appropriate to the cargo and voyage.
- Assess flag state due diligence, including registries associated with weak oversight of sanctioned trade.
- Identify vessels operating without standard insurance as a strong indicator of sanctions exposure.
- Coordinate with insurers and classification societies to confirm a vessel's compliance status before fixing.
04Escalation, Governance and Decision-Making
2 sessions · 8 points
Session 1Escalating Red Flags under Time Pressure
- Design an escalation workflow that routes a red-flagged cargo to compliance before a fixture is confirmed.
- Balance commercial pressure to fix a cargo quickly against the time needed for adequate due diligence.
- Make and document a defensible decision when available information is incomplete or contradictory.
- Coordinate escalation between trading, legal, compliance and senior management for high-risk cargoes.
Session 2Building an Ongoing Due Diligence Programme
- Design a due diligence programme that screens repeat counterparties and vessels on a recurring basis, not only at first contact.
- Update screening criteria as sanctions regimes, price cap rules and evasion techniques evolve.
- Train trading and operations staff to recognise red flags before a cargo reaches the compliance team.
- Report due diligence programme performance and emerging risk patterns to senior management and the board.
What the participant receives
4 course modules
A structured syllabus
8 training sessions
across 5 days
32 detailed points
Applied, detailed content
Accredited attendance certificate
On completing the programme
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