Questions this guide addresses
- Have beneficial owners and controllers behind the contracting parties, and the actual recipients of money, goods and fees, been identified?
- Have current official lists and rules been selected to match the jurisdictions, currency, banks, ports, vessel and cargo?
- Who resolves potential matches or vessel anomalies, with which evidence, and who approves suspension or resumption of the transaction?
Method and verification scope
- We reorganized official UN sanctions lists, FATF guidance on beneficial ownership and trade-based money laundering, and the IMO identification system into checks by transaction stage.
- Corporate entities, ownership, funds, cargo and vessels are cross-checked within one network from contract to shipment, documents and payment, rather than treated as separate searches.
- Automated searches, commercial data or AIS signals alone must not determine a legal conclusion. Review by specialists in the relevant jurisdiction should use current official materials, unique identifiers and original evidence.
01 · Scope the transaction
Identify all participants connected to the transaction, not just one company
The first step is to define the transaction's scope, not type the seller's name into a search box. Record the parties' countries of incorporation, place of performance, goods' origin and destination, payment currency and banks, ports of call, vessel flag, locations of participating companies and contractual sanctions clauses. Applicable sanctions, export-control and anti-money-laundering rules depend on these facts and jurisdictional connections.
Map the buyer, seller, parent company, beneficial owners and controllers, brokers, local agents, fee recipients, banks, carriers, registered owner, actual operator, ISM manager, charterer, insurers and final consignee. Use different lines for contracts, ownership and control, funds and logistics. This helps identify participants who control or benefit from the transaction without appearing in the contract.
02 · Identity & ownership
Verify legal identity and ownership and control using unique identifiers
Verify a company through incorporation documents, a current registry extract, articles, registered address, company and tax numbers, directors and representatives, signing authority and account holder name. Do not rely solely on a website or business-card trade name. Check that the contract's legal name, registration number and address consistently match invoices, accounts and shipping documents. Retain translated names, abbreviations and former names as aliases, while using the original legal name as the reference record.
Trace the ownership chain from direct shareholdings to the ultimate natural person or a verifiable higher controlling entity. Separately ask about voting rights, director appointment rights, contractual control and joint control. Beneficial ownership and sanctions-related ownership and control tests may differ by jurisdiction. Do not apply one shareholding threshold mechanically to every global transaction. Log discrepancies between submitted materials and official registry records, with verification dates, issuers and supporting evidence.
Sources [4]
03 · Sanctions screening
Separate list selection, potential-match resolution and rescreening
Sanctions review cannot be completed using a single global list. Select current official UN and relevant national or regional lists, financial-institution rules and contractual requirements based on the transaction's connections. Do not classify a transaction as prohibited merely because it involves a country or high-risk region. Check each program's prohibited conduct, targets, ownership and control, licenses and exceptions in the current source text.
Search legal names, original spellings, transliterations, former names and aliases, then narrow results using unique identifiers such as date of birth, nationality, address, company registration number, passport number or vessel IMO number. Record no match, resolved potential match, confirmed match or unresolved due to insufficient information. Preserve the list version, search date, query and evidence. A potential match is a reason for further review, not proof of a violation.
04 · Vessel due diligence
Track vessels and responsible parties by IMO number, not vessel name
Do not identify a vessel by name alone. Using its IMO number, verify current and former names, flag, registered owner, actual operator, ISM manager, charterer, classification and liability insurance, with the reference date for each. Track the same vessel through name, flag and ownership changes. Check whether the party contractually responsible for carriage matches the actual operating, insurance and documentary parties.
Compare port calls, expected routes and AIS records with bills of lading, shipment dates, cargo origin and quantity, and inspection certificates. Prolonged AIS gaps, unusual routes, unclear ship-to-ship transfers and repeated name, flag or ownership changes over a short period may require more evidence. AIS can be incomplete because of reception coverage, equipment faults, safety considerations or data quality. One signal cannot establish position manipulation or sanctions evasion.
05 · Transaction consistency
Check that contracts, cargo, transport and payment records describe the same transaction
Cross-check product descriptions, quantities, dates, shippers and consignees, ports and vessels across contracts, orders, commercial invoices, packing lists, certificates of origin, bills of lading, inspection and quality certificates, insurance and customs records. If contracted goods differ from transport descriptions, or origin, destination or transshipment routes change late, verify the commercial reason and authority for the change. Determine classification, export controls and licensing using current rules and technical specifications.
For fund flows, compare the contractual payee and account holder, bank location, payment currency, third-party payments, advances and fees. Escalate personal or unrelated-company accounts with no explained transaction link, last-minute payee changes and unusual payment splitting. Even with a plausible explanation, do not change payment details based on email alone without delegated authority, an amended contract and bank confirmation.
06 · Decision & monitoring
Connect decisions, conditional progress and later reviews through a documented record
Use operational due diligence outcomes such as proceed, conditional proceed, specialist escalation and do not proceed. For conditional progress, set completion criteria and deadlines for additional documents, exclusion of particular parties, confirmation of the paying bank, use of approved vessels only or pre-shipment rescreening. Unresolved potential matches and legal interpretations must go to designated compliance or legal approvers, not be resolved unilaterally by sales.
After signing, continue reviewing lists, ownership, vessels, banks, routes and the expiry of official licenses. Party changes, unusual payment requests, vessel substitutions, route deviations, ownership or flag changes, official list updates and new facts trigger event-based diligence. Preserve searches, resolution evidence, approvals and notices. Limit personal-data access and retention to what is needed for the stated purpose.
A risk-signal review checklist
A due diligence checklist for deciding what additional evidence and approvals are needed, not a set of automatic rejection rules.
| Observed signal | Minimum further verification | Escalation condition | Interim action |
|---|---|---|---|
| Mismatch in legal name, address or number | Current registry extract, change history, signing authority and account holder | Unexplained difference or a separate entity presented as the same company | Pause the relevant stage until correction and independent verification |
| Break in the ownership or control chain | Holdings, voting rights, control agreements and ultimate beneficiaries at every level | Refusal of information or conflicting structure charts | Enhanced diligence and jurisdiction-specific legal review |
| Potential official-list match | Date of birth, nationality, registration number, passport, IMO number and similar identifiers | Unique identifiers match or information is insufficient | Pause the activity for specialist resolution rather than automatically reject |
| Unrelated agent or third-party account | Role, services, fees, ownership, authority and banking records | Mismatch in service evidence, payment purpose or account holder | Separately hold the third-party payment |
| Repeated name, flag or manager changes | IMO-based history, registration, class and insurance | Dates or parties conflict with documents | Establish responsible parties before vessel approval |
| AIS gap, route deviation or transshipment | Raw data, reception coverage, logbook, port and cargo records | Independent data conflict or gaps cannot be explained | Specialist review without concluding from one signal |
| Mismatch among contract, bill of lading and payment | Original issuers, amendment history, inspection, customs and bank records | No economic explanation or authority for amendment | Hold only the affected cargo or payment |
All signals are indicators for further review, not evidence of sanctions violations, deception or illegality. Conclusions must use transaction-specific facts, applicable law, current official sources and resolution evidence.
Practical takeaways
- Before searching names, build the network of contractual, ownership, payment and logistics relationships and each participant's unique identifiers.
- Recheck sanctions lists and vessel information whenever the transaction changes stage, including contracting, shipment, document presentation and payment.
- A red flag, AIS gap or potential name match is a reason for further review, not evidence of a sanctions violation or deception.
Sources and further reading
Source titles are preserved in their original language. Figures retain the reference period stated by each source.
- United Nations Security CouncilUnited Nations Security Council Consolidated List ↗
The official consolidated list of individuals and entities subject to UN Security Council sanctions.
Accessed 2026-08-31 - International Maritime OrganizationIMO Identification Number Schemes ↗
The IMO numbering system for persistent identification of ships, companies and registered owners.
Accessed 2026-08-31 - International Maritime OrganizationGlobal Integrated Shipping Information System (GISIS) ↗
The IMO's official public portal for shipping and maritime information.
Accessed 2026-08-31 - Financial Action Task ForceGuidance on Beneficial Ownership of Legal Persons ↗
Official FATF guidance on obtaining beneficial ownership information for legal persons and verifying it on a risk basis.
Published / revised 2023-03-10 · Accessed 2026-08-31 - Financial Action Task ForceTrade-Based Money Laundering: Risk Indicators ↗
TBML risk indicators observable in trade documents, goods, corporate structures and accounts, with cautions on interpretation.
Published / revised 2021 · Accessed 2026-08-31 - UK Office of Financial Sanctions ImplementationFinancial sanctions guidance for maritime shipping ↗
Official guidance on shipping participants, vessel, cargo and route risks, and due diligence considerations.
Accessed 2026-08-31