Ships and other vessels guidance

Summary

This JFSC guidance document provides practical risk indicators and good practice examples for regulated entities that encounter ships, yachts, or other vessels (and by extension aircraft) in their business relationships, such as when a client or trust structure owns, leases, or uses a vessel. It is intended to support AML/CFT risk assessment and due diligence rather than to impose new binding rules.

• Risk factors: Highlights how vessels can be misused for smuggling, human trafficking, drugs trafficking, wildlife smuggling, cargo fraud, terrorist financing, sanctions evasion (including AIS manipulation and ship-to-ship transfers), and use of flags of convenience to avoid regulation.
• Good practice checks: Suggests documenting and, where necessary, acting on details such as vessel name, type, IMO number, flag, sanctions screening, ownership and leasing structure, crew and lessor/lessee vetting, cargo verification, valuation, insurance, logbook checks, and links to higher risk jurisdictions or designated persons.
• Ongoing due diligence: Recommends firms satisfy themselves as to the legitimate current and ongoing use of the vessel, retain evidence of due diligence, and consider professional advice sought by themselves and other involved parties.
• Aircraft: States that similar considerations apply to aircraft as to ships.

The document does not set out specific deadlines, filing requirements, or mandatory procedures; it is advisory guidance to inform risk assessments and control frameworks already required under AML/CFT obligations.

Applies to

Regulated financial services businesses, trust and company service providers, other entities conducting AML/CFT risk assessments involving ships or vessels