Heard about Hurds bank?

No, it’s not a Bank, it’s an offshore bank located east of Malta (35°53'N 14°45'E) and hardly visible on the map

What about Hurds bank?

If I say bypassing sanctions, do I have your attention?

Since at least 2015, Russia, Venezuela, Iran, Syria, Libya and even North Korea as well as terrorist organizations such as Hamas and Hezbollah, have been reported to be using Hurds bank to bypass sanctions, especially US sanctions. An informal ship-to-ship network has been established at Hurds bank in which products (i.e., oil, chemicals and other goods) are transferred between large ships with different destinations, including both to and from sanctioned regimes

Hurds bank is important, especially if you are a Nordic financial institution with shipping customers with a large shipping fleet, and for Nordic shipping company that don’t want to be involved in sanctions evasions schemes

Currently at least one Nordic company is represented at Hurds bank, the Danish shipping company group MØLLER MAERSK with their oil tanker VS REMLIN (IMO 9252307), operated by MAERSK TANKERS A/S subsidiary HANDYTANKERS K/S, which departed from the Russian port of Tuapse, Krasnodar Krai.
The US sanctioned ROSNEFT is well represented in Tuapse, and ROSNEFT is no stranger to US sanctions not only on them but on their partners (i.e., sanctioned regimes such as Venezuela)

The government of Russia has at least one ship represented there, the oil tanker ALEKSEY KOSYGIN (IMO 9316127), sailing under the flag of Liberia and operated by SCF MANAGEMENT SERVICES DUBAI, a subsidiary of the Russian state own SOVCOMFLOT, known for its close connection to Russian security and military services. SCF is also represented in Norway with its subsidiary SCF GEO AS. Another shipping company known to have strong business ties with SOVCOMFLOT (SCF) over several years is the Swedish STENA group

How to mitigate potential sanctions risk exposure?

First, minimum requirement is to screen your customers counterparties against sanctions (however, this will most likely not result in any “true target match”)

Secondly, have a proactive approach to this risk. Start with requiring from your shipping customers that they shall have at least a Sanctions Policy, even better if they also sanctions screen their counterparties involved in the entire shipping chain

Third, which ships in your customers fleet are currently located near or at Hurds bank? What kind of ships is this? Where are they coming from? Where are they heading?

Sanctions risks are not only about screening against sanctions, it’s about staying ahead and avoiding being involved in sanctions evasions schemes

NOTE! non of the companies profiled are alleged sanctions evaders or violators, they are merely there as examples.