Sanctions screening and export control
How a vessel, its ownership and the counterparty raising the order are screened before we quote, and the work we decline.
The standing position
Every engagement is subject to sanctions screening and to applicable export-control law: a quotation, an attendance, a calibration, a survey and the supply of a part alike. The position does not change with how the work is delivered. It applies to work carried out from our own service bases in İstanbul, İzmir, İskenderun, Varna, Constanța and London, to regional mobilisation from one of those bases, and to work delivered through a partner firm at a port where we hold no base. A partner is screened before it is instructed, and the same restrictions are passed down in the order we place with it: every order carries a written clause requiring the partner to comply with the measures set out below, to confirm that neither the firm nor the personnel it will send are designated, and not to subcontract the attendance further without telling us. A firm that will not accept that clause does not receive the order. This statement is owned by an operations director accountable for sanctions compliance. It is reviewed once every twelve months, and again within one month of a change to a measure that reaches this trade.
Why a marine service supplier screens
An attendance is never one counterparty. It involves a vessel, its registered owner, its operator and technical manager, its flag administration, in most cases a charterer, the agent or manager who raises the order, and a port with its own authority and terminal operator. Any one of them may be a designated person or entity, or sit in a sector that restrictive measures reach. Sending a technician on board before that has been checked exposes the customer and this company to the same breach, which is why the check is made before anyone travels and before a price is given.
What is screened, and when
We screen the vessel by name and IMO number, its registered owner, its operator and technical manager, its flag, the counterparty raising the order — owner, manager, charterer, agent or broker — and the port and terminal of the attendance. Screening is run twice: once before a quotation is issued, and again before mobilisation. The second run is not a formality. Designations are added, ownership is restructured and vessels are renamed between a quotation and a port call, so a vessel that was clear on the first check is not assumed to be clear on the second. Screening is carried out against the consolidated lists published by the authorities named below, read from each authority’s own current list on the day the screening is run rather than from a copy taken earlier, and a record of each screening — what was checked, against which lists, on what date and by whom — is retained for six years from the date of the attendance, or from the date of the quotation where no attendance follows.
The measures we screen against
United Nations Security Council measures. European Union restrictive measures. United Kingdom measures — the UK Sanctions List maintained by the Foreign, Commonwealth and Development Office under the Sanctions and Anti-Money Laundering Act 2018, financial sanctions administered by the Office of Financial Sanctions Implementation at HM Treasury, and trade sanctions administered by the Office of Trade Sanctions Implementation at the Department for Business and Trade. United States measures administered by the Office of Foreign Assets Control, including the Specially Designated Nationals and Blocked Persons list. Our bases, our people and our equipment sit in Türkiye, Bulgaria, Romania and the United Kingdom. Bulgaria and Romania apply European Union measures. Türkiye implements United Nations measures and does not adopt the autonomous European Union, United Kingdom and United States designations — we apply them there as a matter of policy, not because Turkish law compels it. The measures that reach settlement follow the invoicing entity and its banking channel, which are set out under payment routing below. Where the regimes that apply to an engagement differ, the strictest of them governs what we will do, with one qualification we would rather state than leave for a reader to discover: Council Regulation (EC) No 2271/96 prohibits a person in the European Union from complying with the extraterritorial measures listed in its Annex, so our Bulgarian and Romanian bases apply United States measures only so far as European Union law permits, and where the two conflict European Union law governs at those bases.
Ownership, control and vessel identity
A vessel does not have to be listed by name to be within scope of the restrictions. Ownership and control are what decide it: a designated person or entity owning more than 50 per cent under the European Union and United Kingdom tests, 50 per cent or more under the United States rule, directly or through intermediate holdings that aggregate — or otherwise exercising control. Where that test is met, the restrictions extend to the company and to the vessels it owns or operates. We therefore look at registered owner, operator, technical manager and, where it can be established, beneficial ownership — not only the name on the certificate of registry. A change of flag, a change of name, a newly appointed manager or a fresh entry in a register does not clear a vessel. A gap in AIS transmission points the other way: an unexplained loss of signal, a transmitted position that does not match where the ship is, or a ship-to-ship transfer at sea is a reason to look harder, not a neutral fact. Where ownership or control cannot be established to our satisfaction, we treat the vessel as though it were designated.
Ports we do not attend
Some ports inside the regions we otherwise cover are outside our coverage on sanctions grounds. They are not listed in the coverage index, not searchable within it, and not counted in the 300 ports it publishes across 15 regions. That is a decision taken once and applied to the data itself, not a gap in the network and not a base we have yet to open. A request for a quotation at one of those ports produces a refusal, not a price. Which ports, destinations and flag administrations are excluded is not published as a list here: the exclusion follows the measures and moves with them, and a list printed on a page would be out of date before it was read. The position on a named port, destination or flag is given in writing within one working day, on request to compliance@shipcertify.com, and a supplier questionnaire that asks for it is answered the same way.
Dual-use items and controlled supply
Part of what we supply is controlled. Radio transmitting equipment, satellite terminals, radar, thermal and night-vision equipment and certain test, measurement and calibration instruments can fall within dual-use control lists, and the control follows the item across a border whoever is buying it. Before supply we establish the end use and the end user, the vessel and the port the item is being shipped to, and whether onward transfer or re-export is intended after delivery. We do not supply where an export licence would be required and is not held, and we do not accept a customer assurance that a controlled item will be used for something other than the purpose its specification states. Where a licence or authorisation would be required for a supply — by the jurisdiction the item is exported from, or by the destination — we do not proceed until it is in place: the order is held, the customer is told in writing that it is held and why, and if the licence is refused the order is cancelled and anything already paid against it is returned. Before a controlled item is released we ask for a written end-use statement naming the vessel, its IMO number, the port of delivery and what the item is for, and we do not ship without it.
When we decline work
Where screening produces a match that cannot be cleared on the evidence, or where ownership, control or end use cannot be established, we decline. We do not look for a reading of the measures that would permit the work, and we do not accept a warranty from a customer in place of an answer. A refusal is given in writing, with the reason stated so far as the law permits us to state it, and it is not negotiable: the same scope on the same vessel put to us again receives the same answer. Work already in hand stops if a designation lands during an attendance. The decision to decline is taken by an operations director rather than by the person who priced the enquiry, and it is recorded with the evidence it rests on. A customer may ask once for that decision to be looked at again, by writing to compliance@shipcertify.com with evidence that was not before us the first time; the review is carried out by an operations director who took no part in the original decision, and is answered within five working days. Evidence is what reopens a refusal. Nothing else does.
Payment routing and correspondent banking
How an invoice is settled is part of the same check. We invoice the counterparty named on the order and take settlement only from that counterparty, in its own name, through the banking channel printed on the invoice. We do not take payment from an unrelated third party, we do not re-address or split an invoice to route a payment differently, and we do not accept cash in place of a banking channel. A correspondent bank may delay, reject or return a payment for its own compliance reasons; that is a matter between the payer and its bank, and the invoice stands until we are actually paid. The entity that invoices an engagement, and the account it is settled to, are named in the quotation and repeated on the invoice. Payment is made only to the account stated on our invoice. We do not act on a request to route a payment to a third party, to another account or to another jurisdiction, whoever it appears to come from and whatever reason is given for it — so if you receive one in our name, do not pay it: telephone the İstanbul office on +90 216 446 55 00, or write to accounts@shipcertify.com, and have it confirmed first.
Raising a concern
If you believe an engagement of ours would breach a measure, or you hold information about the ownership, control or trading pattern of a vessel we are attending, write to compliance@shipcertify.com. A report is acknowledged within the period set out in the complaints and appeals procedure on this site, and is assessed before any further attendance on that vessel proceeds. A report may be made in confidence — say so in the message. Where a report obliges us to notify a competent authority, we notify it.
Contact
compliance@shipcertify.com for anything on this page, including a supplier-qualification questionnaire that asks how we screen; those are answered in writing, with a quotation or on request. Commercial enquiries and quotations go to sales@shipcertify.com or info@shipcertify.com, and the operations desk runs 24 hours a day on +90 532 657 48 78. A formal notice under this statement is given in writing to compliance@shipcertify.com, addressed to the operations director accountable for sanctions compliance — we name the role and not an individual, because the person answering is whichever director holds that responsibility on the day — and by post to Office 7408, 58 Peregrine Road, Hainault, Ilford, Essex IG6 3SZ, United Kingdom. A written notice is acknowledged within one working day. Where the vessel is alongside, telephone the operations desk first and follow it in writing: alongside, the answer has to come in hours.
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