How Smuggling Networks Use the Same Tactics as Sanctions Evaders

The tactics employed by smuggling networks and those evading sanctions are strikingly similar, with the same playbook being used for both illicit activities. Vessels loaded with crude oil at sanctioned terminals and those carrying cocaine from Colombian beaches share the common goal of moving cargo across international waters into ports without leaving a detectable trail.

To accomplish this, both groups utilize techniques that go beyond commodity-specific methods. One such technique involves "going dark," which entails ceasing transmissions at a critical point where records would be most scrutinized, such as the point of recordation. This is followed by transferring cargo at sea, thereby concealing the vessel that initially loaded the cargo.

Another common tactic is changing the vessel's flag, name, and Maritime Mobile Service Identity (MMSI), effectively altering the vessel's history and making it difficult to trace its origins.

The compliance and enforcement communities have traditionally viewed these issues as separate problems with distinct solutions. However, at the vessel behavior layer, they are fundamentally the same issue. An AIS (Automatic Identification System) gap does not provide any explanation on its own; it merely indicates that a vessel stopped transmitting for a specific duration, followed by a resumption of transmission.

For sanctions analysts, a vessel going dark near a designated terminal may suggest an attempt to obscure a port call, while counter-narcotics officers might interpret the same behavior as an attempt to conceal a meeting.

Windward, a counter-narcotics assessment group, identified a vessel carrying illicit cargo as a textbook example of exploiting phantom registries, deliberate AIS manipulation, and corporate opacity to evade detection. This vessel changed its declared destination, transferred cargo at sea, and switched its flag and name to maintain an untraceable history.

Similar cases have been observed, where vessels went dark for varying durations, surfaced briefly at private wharfs for calls, and then resumed their journey, sometimes empty-handed.

Ship-to-ship transfers serve as a crucial technique that bridges the gap between sanctions evasion and drug trafficking. By moving cargo between vessels with clean profiles, smugglers can break the link between the cargo and its origin. This technique is detectable through imagery, regardless of the vessel's AIS status, as two hulls alongside are visible in EO (electro-optical) and SAR (synthetic aperture radar) imagery, even if they are not transmitting.

However, detection at the mothership end of the chain is more feasible than at the receiving end due to the high-speed nature of some transfer operations.

Flag-hopping, MMSI changes, and renaming are all tactics designed to break the vessel's history and make it appear as if it were a clean entity. A vessel with a documented pattern of illicit behavior may reflag, rename, and reappear as a nominally clean vessel, appearing unremarkable on the surface but traceable when screened against ownership networks and behavioral history.

The flag itself has become a telltale sign, as Mali-flagged vessels have been identified as fraudulently broadcasting its flag due to fraudulent registration practices. This alteration in flag status is as relevant to customs officers as it is to compliance analysts assessing the risk posed by a particular counterparty.