When sanctions enforcement creates new risks for shipping

When sanctions enforcement creates new risks for shipping
January 7, 2026 https://splash247.com/when-sanctions-enforcement-creates-new-risks-for-s...

Graeme Morkel, deputy international registrar of shipping and seamen at the St Kitts and Nevis International Ship Registry, writes for Splash today.

The shipping industry is under increasing pressure to play its part in tackling illicit and illegal trade. Sanctions evasion, flag hopping and complex ownership structures are no longer marginal issues. They are now central to the integrity of the global fleet and to the credibility of flag states.

Open registries in particular are often portrayed as part of the problem. In reality, many are now on the front line of enforcement.

Recent engagement between ship registries and international stakeholders has reinforced a basic but uncomfortable truth.

Flag states cannot be treated as both enforcers and fall guys

Flag states are being asked to act on intelligence driven decisions that carry real operational and human consequences, yet the frameworks that sit around those decisions have not kept pace.

One of the more meaningful steps forward has been the move towards structured intelligence sharing between registries. The Registry Information Sharing Compact, known as RISC, allows flag states to share information on vessels that have been denied registration or are under sanctions related investigation. Its purpose is straightforward. To prevent vessels with problematic histories from moving between flags to avoid scrutiny.

This matters because flag hopping is not an administrative loophole. It is a deliberate strategy used by operators seeking to continue trading despite clear concerns around compliance. Without shared visibility, registries are left making high risk decisions in isolation. That is a position no responsible flag state should be placed in.

What is often overlooked is how closely registries now work with international enforcement and intelligence bodies. Decisions to remove or deny registration are frequently taken following direction based on intelligence supplied by organisations focused on sanctions enforcement and national security. In these situations, flag states are not acting independently. They are responding to international instruction.

The difficulty arises when the consequences of those actions are later reframed. When a vessel is removed from a registry following a directive, it can quickly be labelled as abandonment, with responsibility implicitly assigned to the flag state. This is a dangerous and misleading narrative. Enforced removal in support of sanctions compliance is not abandonment. Treating it as such undermines the very system that international enforcement relies upon.

There is a clear need for better alignment between the United Nations, the IMO and flag states on how these actions are defined and communicated. If flag states are expected to enforce sanctions decisively, there must be clarity and backing when the outcomes are challenging. Without this, registries are exposed to reputational, legal and operational risk for doing exactly what they have been instructed to do.

There are encouraging signs that this issue is beginning to be recognised at an international level. Discussions around sanctions frameworks and closer cooperation with the IMO suggest a growing awareness that enforcement cannot exist in isolation. Responsibility must be shared and accountability must be consistent.

The fight against illicit trade in shipping depends on trust, transparency and cooperation. Flag states cannot be treated as both enforcers and fall guys. If the industry is serious about closing the door on illegal activity, it must also stand behind those tasked with doing the closing.