What is the OFAC Maritime Advisory and why does it matter?
OFAC has issued sector advisories (notably the 2020 Maritime Advisory and successor guidance) outlining expected due-diligence practices for the maritime industry — including KYC on counterparties, monitoring AIS for manipulation, screening vessels and beneficial owners, and contractual sanctions clauses. The expectations apply de facto to anyone in the shipping value chain and are routinely cited in enforcement actions.