SAN003 · Sanctions

Transshipment

Transshipment Evasion is the routing of goods through an intermediary jurisdiction to disguise their true origin or destination and defeat origin-based sanctions controls. Cargo that could not move directly between two points is re-papered at a hub — a free zone, an entrepôt — so the declared trade route no longer reveals the sanctioned leg.

The finding is a routing finding: it lives in the mismatch between declared and true origin, the number of transshipment hops, and the presence of a restricted commodity, corroborated by maritime behaviour and the jurisdictions involved.

Risk indicators

Trade-Routing

• Declared origin ≠ true origin
• One or more transshipment hops through a known hub
• Restricted / controlled commodity
• Generic goods descriptions on high-value cargo

Maritime

• AIS transmission gaps on the true leg
• Ship-to-ship transfers near the hub

Jurisdiction

• True origin in a sanctioned jurisdiction
• Hub in a high-risk free zone

Counterparty

• Counterparties carrying sanctions exposure or adverse media

Investigation actions

1. Resolve the shipment, its declared and true origin, and the hub.
2. Test declared origin against true origin for a mismatch.
3. Count transshipment hops and identify the hub.
4. Assess restricted-commodity status.
5. Aggregate maritime behaviour (AIS gaps, STS transfers).
6. Score jurisdiction exposure for the true origin and hub.
7. Score counterparty exposure.
8. Aggregate; escalate at or above the threshold.

Detection logic

1. Resolve the shipment, its declared and true origin, and the hub. 2. Test declared origin against true origin for a mismatch. 3. Count transshipment hops and identify the hub. 4. Assess restricted-commodity status. 5. Aggregate maritime behaviour (AIS gaps, STS transfers). 6. Score jurisdiction exposure for the true origin and hub. 7. Score counterparty exposure. 8. Aggregate; escalate at or above the threshold.

Related typologies

Curated from fc-05-sanctions-exposure-analytics-toolkit/typologies/SAN003_Transshipment.md