The growing complexity of sanctions regimes and increasingly sophisticated deceptive shipping practices have made vessel checking an important, but difficult, element of trade finance compliance.

The ICC's new Financial Crime Risk Controls: Vessel Checking Guide, published in July 2026, is therefore timely. Its particular value lies in recognising both the importance of vessel checking and the practical limits of what banks can reasonably achieve.

Financial institutions handling documentary trade have access to information that may not be available in an ordinary payment transaction. Bills of lading can provide vessel, carrier, cargo and routing information, potentially helping identify sanctions evasion, fraud and trade-based money laundering. However, the Guide makes an important distinction in that having access to shipping documentation does not mean that every maritime risk can, or should, be identified from it.

This is particularly relevant as regulatory guidance increasingly highlights practices such as AIS manipulation (interfering with, falsifying or misleading the information transmitted through a vessel's Automatic Identification System), ship-to-ship transfers, flag changes and the activities of dark or shadow fleets.

These behaviours will generally not be visible on the face of normal transaction documents. Identifying them requires external maritime data, specialist expertise or direct verification.

The Guide therefore advocates a two-layer approach with baseline document-based checking during normal transaction processing, followed by enhanced investigation where defined risk indicators justify it.

Operationally this is important because a blanket requirement to conduct extensive external vessel investigations for every sea shipment would be costly and could generate considerable noise without necessarily improving financial crime detection.

The Guide instead favours targeted controls based upon factors such as the nature of the transaction, commodity and jurisdictions involved. Higher-risk oil or petroleum trades, for example, may justify analysis of vessel behaviour that would have little relevance to an ordinary containerised shipment.

Technology inevitably has a role, and external maritime data can help identify unusual vessel movements and validate whether a reported shipment could reasonably have occurred. Bill of lading and container tracking can provide further insight into routes and transhipments.

Nevertheless, technology works best when supported by better data, and one particularly practical recommendation is wider, potentially mandatory, inclusion of the vessel's IMO number on bills of lading. Unlike vessel names, which can change and generate false screening matches, the IMO number provides a more reliable identifier.

There is also a wider message recognising that banks cannot solve maritime financial crime through documentary trade controls alone. The Guide notes that only around 20% of global trade is supported by trade finance, meaning much trade takes place without transport documents ever reaching a financial institution.

Effective vessel checking therefore requires proportionate controls, better data and greater collaboration between banks and the wider maritime ecosystem.

The objective should not be to check everything simply because technology makes more checking possible, but to identify where the risk genuinely lies and apply the right level of scrutiny there.

Source: ICC Financial Crime Policy Taskforce

This article represents the views of the author and not necessarily those of ICC.