Banking and finance

Financial crime risk controls: Vessel checking

31 July 2026

Trade finance transactions involving sea shipments can provide financial institutions with unique visibility into the movement of goods, offering valuable opportunities to detect sanctions evasion, trade-based money laundering, fraud and other forms of financial crime. Developed by a working group of ICC’s Financial Crime Policy Taskforce, this guide explores challenges and best practices for financial institutions in identifying financial crime risks in trade finance transactions involving ocean shipment. It reviews regulatory considerations, outlines common deceptive shipping practices and sets out practical recommendations for implementing effective vessel screening controls.

As sanctions regimes expand and deceptive shipping practices become more sophisticated, financial institutions face growing challenges in identifying financial crime risks linked to ocean-borne trade. Yet despite increasing regulatory scrutiny and technological advances, detecting illicit activity within global shipping networks remains a complex and resource-intensive task.

Financial institutions have an important role to play in combating financial crime. In particular, trade finance involving ocean shipment can sometimes provide institutions with a level of visibility that allows greater opportunity to detect illicit activity. However, the issue is complex and challenging.

This guide highlights the scale of the challenges, common approaches and recommendations on controls, and the need for increased collaboration across the maritime industry, regulators, enforcement agencies and financial institutions. It also provides greater clarity on the role of financial institutions in vessel compliance checks, helping define what they should reasonably assess while recognising that responsibility for compliance vetting extends beyond banks alone.

Key report insights

Trade finance offers a unique line of defense

Financial institutions involved in documentary trade transactions often have access to shipping documentation that is unavailable in other banking products. This additional visibility can help identify suspicious activity, fraudulent documentation and potential sanctions breaches.

Regulatory expectations are increasing

Recent guidance from sanctions authorities has placed greater emphasis on identifying deceptive shipping practices, including ship-to-ship transfers, AIS manipulation, false flag operations and the use of complex ownership structures to conceal sanctions exposure.

Effective controls require a risk-based approach

Not all maritime trade presents the same level of risk. Institutions should focus enhanced vessel screening efforts on higher-risk commodities, trade corridors and jurisdictions while maintaining proportionate controls for lower-risk transactions.

Collaboration is essential

Financial institutions alone cannot address maritime financial crime risks. Improved information sharing between the public and private sectors, combined with greater standardisation of shipping data, will be critical to strengthening the effectiveness of controls across global supply chains.

Key recommendations

Prioritise enhanced checks for higher-risk transactions and commodities.
Promote mandatory inclusion of IMO numbers on Bills of Lading.
Leverage maritime intelligence, technology and third-party data sources.
Strengthen collaboration between financial institutions, shipping stakeholders and authorities.
Continuously review and update controls in response to evolving risks and regulatory expectations.