Unmasked

Report

September 9, 2021

By: Andrew Boling Lucas Kuo Luke Snyder Lauren Sung

The Bottom Line Up Front

Unmasked uses North Korea case studies to show how stakeholders across the maritime domain can apply the same methods to detect cases of vessel identity laundering and take steps to mitigate this risk.

Executive Summary #

Vessel identity laundering operations jeopardize the integrity of the International Maritime Organization (IMO) ship registration system, which the world relies upon in order to identify, track, and interact with the 60,000 ships that travel the world’s oceans transporting 90% of global trade.

Vessel identity laundering is a novel tactic in which one or more vessels adopt a different identity on Automatic Identification System (AIS) transmissions in order to allow “dirty” (i.e. associated with illicit activities) ships to assume “clean” identities, and involves at least one vessel in this operation assuming an identity that is obtained by defrauding the IMO. Vessel identity laundering is significantly more sophisticated than previously observed instances of “vessel identity tampering,” in which vessels modify their physical appearance or broadcast false data on AIS transmissions. Given its complexity, vessel identity laundering presents unprecedented challenges for maritime regulators and risks undermining global shipping practices.

In recent years, C4ADS has observed at least 11 ships engaging in elaborate schemes to create fraudulent ship registrations with the IMO, which are subsequently used to “launder” the identity of vessels that have been associated with illicit activities. In particular, we have seen networks involved in DPRK sanctions evasion and smuggling use these tactics to avoid the heightened scrutiny of the sanctions regime.

This issue brief seeks to empower law enforcement and civil regulators to detect and disrupt vessel laundering identity operations by explaining how vessel identity laundering operations work and demonstrating how they can be detected using AIS data, satellite imagery, IMO registration records, and other sources of publicly available information. We cover two previously unreported case studies of vessel identity laundering involving DPRK fuel smuggling networks:

The KINGSWAY (IMO 9191773), sanctioned by the UN Security Council (UNSC) for engaging in a ship-to-ship transfer with a North Korean tanker, laundered its identity into the APEX/SHUN FA (IMO 8528864) in late 2018.
The SUBBLIC (IMO 8126082), recommended for designation by the UN Panel of Experts for numerous deliveries of fuel to North Korea, laundered its identity into the HAI ZHOU 168 (IMO 8514045) in mid-2019.

This report finds that in order to counter vessel identity laundering, the IMO and other maritime regulators must take steps to strengthen due diligence processes to secure a ship’s registered, digital, and physical identities. We offer recommendations to prevent the proliferation of fraudulent ship identities and mitigate risk by improving data collection, authentication, and transparency.