On 3 November 2022, OFAC listed the tanker ADISA, IMO 9304667, and its entry gives Panama as the flag. On 10 December 2025, US law enforcement seized the same hull on the high seas as the Skipper, and the Justice Department says it was claiming a false Guyanese flag at the time, "rendering it stateless". On 28 October 2026, OFAC's list still named IMO 9304667 as ADISA, with no alias.
What does vessel identity laundering mean?
Vessel identity laundering is giving a sanctioned ship an identity that belongs to another vessel, or to none, so it can load cargo, buy insurance and get paid as someone else.
The term comes from the UN Panel of Experts on North Korea. Its final report of 7 March 2024 describes an identity swap: a "clean" ship with no record of sanctioned trade "frees up its digital identity to a 'dirty' ship". The clean ship is altered, passes as newly built and obtains a different IMO number. Its old AIS profile, now tied to no hull, can be broadcast by more than one ship.
In wider use the term covers every way a listed hull hides, and each runs into one fixed point: the IMO number stays with a ship for its lifetime. So a ship is screened by that number and again when its name, flag or owner changes, the loop that client screening and ongoing monitoring runs on people and companies.
How do sanctioned ships change their identity?
Table 1. Seven ways a ship hides its identity, and the check that catches each
| Technique | What it hides | Red flag | Check that catches it |
|---|---|---|---|
| Identity swap | the listed hull, behind a clean ship's IMO number and AIS profile | particulars (type, tonnage, year of build) that differ from the IMO record | the ship's particulars matched to the record for its number |
| AIS spoofing | the position, name or IMO number the ship broadcasts | an AIS name or number that differs from the papers; gaps near transfer areas | AIS history from a data provider, read against the papers |
| Painted over name and number | the identity on the hull | hull markings that differ from the certificates | photos and inspection reports against the certificates |
| False flag or fraudulent registry | the lawful flag state, or the lack of one | a registry that cannot confirm the ship; a flag kept after deregistration | confirmation from the flag administration; the flag status in GISIS |
| Rename and reflag | the name and flag on the sanctions entry | several names or flags in a short period | an IMO number search that includes every former name |
| Single ship company and owner rotation | the beneficial owner | a new owner or manager just before the voyage | screening of owner, manager and operator |
| Ship to ship transfer | where the cargo came from | a transfer at night or with AIS off | name, IMO number and flag of the receiving ship, checked before the transfer; cargo papers |
The May 2020 advisory of OFAC, the State Department and the US Coast Guard describes AIS spoofing under a different name or IMO number, and hulls with both painted over to pass as other vessels. OFSI's guidance for maritime shipping, updated on 28 January 2026, adds new vessel acquisitions and rotating owner and manager companies.
A UN Panel annex built from Member State reports lists North Korean ships spoofing their identity between 1 April and 15 September 2023. NAM DAE BONG, IMO 9132612, broadcast the name SHUN LI with the number 9298064. Neither was its own. EVER GLORY kept its number, 9102813, and broadcast EVER FENG among other names. The Price Cap Coalition's October 2024 advisory lists the moves owners of sanctioned vessels may try: "renaming, reflagging, obscuring their IMO number, or falsifying documents".
How often do listed ships carry another name or flag?
OFAC lists the crude oil tanker with IMO number 9288851 as CARL, flagged in Barbados, while the UK specified the same hull on 21 July 2025 as GRINCH, flagged in Comoros. Both entries tie it to Cube Ventures Shipping SA. Neither carries the other's name.
OFAC's SDN list of 28 October 2026 and the UK Sanctions List of 30 October 2026 share 301 IMO numbers. For 104 of them, about one in three, the two lists have no name in common, aliases included, and while a few of those are spelling variants such as ALEXEY and ALEKSEY KOSYGIN, most are different names altogether. Flags split more often: 89 of the 197 ships with a flag on both lists show different flags. The EU writes renames into the entry: three of the 117 vessels added by Regulation (EU) 2025/2033 carry a former name, such as BOBCAT (formerly BLOSSOM).
A name from a charter party can match one list and miss another. complead, formerly Sanction Scanner, starts from the number instead in its free vessel sanctions check: the seven digit IMO number gives an exact result, and the check reads the current and former names tied to it on vessel lists from the US, UK, EU and UN, with no account needed.
What are false flags and fraudulent registries?
A false flag is a flag a ship claims without being registered under it. When a flag administration confirms that a ship is not on its register, the IMO's database, GISIS, shows a "false flag" for it, and such a ship can be treated as stateless, as the Justice Department says of the Skipper. A fraudulent registry goes further. An entity claiming to act for a state issues the registration papers, and the UN Panel even found ships flying the flag of a state "where no international registry has existed". The IMO study group keeps the false flag apart from the shadow fleet, which is defined by behavior.
The problem reached the IMO in 2017, when the Democratic Republic of the Congo reported about 73 vessels using its flag fraudulently. The study group's final report counted 101 false flagged ships in GISIS on 11 September 2023. In European waters, data from the European Maritime Safety Agency showed 125 false flagged ships in 1,242 ship to ship transfers between October 2022 and September 2023, and 48 of those ships appeared to fly two false flags in turn within a year. Guyana's flag was misused most often, on 22 ships.
Which 2026 changes touch ship identity?
- 28 January. OFSI closed its consolidated list; UK designations, ships included, now appear only on the UK Sanctions List.
- 13 to 17 April. The IMO Legal Committee approved guidelines on the registration of ships, circulated on 4 June as LEG.1/Circ.19: registries check current and former names, year of build, type and tonnage, and screen owners, managers and financiers before registration and routinely after.
- 23 April. The EU's 20th package took its shadow fleet listings to 632 vessels and kept up outreach to flag states to keep those ships off their registers.
- 23 July. The 21st package added 41 vessels and, for the first time, let the EU list ships that provide services to listed vessels.
- To 1 November. The IMO's communications page lists 13 communications from 11 states dated 2026, against seven in 2025.
How do owners hide behind a laundered ship?
"Changes in the registered ownership of vessels typically occur before sanctioned activities are conducted," the UN Panel wrote. It found actors who do not send updated owner and management details to the IMO, use registered agents as contact points and list throwaway email addresses. Shell and front companies add layers between the ship and its ultimate beneficial owner.
The Price Cap Coalition notes "a recent increase of single vessel fleets": one company, one ship, so a listing of the owner reaches one hull at a time. OFSI asks firms to watch for owner and manager companies that rotate. Companies carry IMO numbers too, which the 2026 guidelines ask registries to verify. So the check continues with the registered owner, manager and operator, each screened by name, for example in a free sanctions check, and their company numbers compared with the ship's history.
Which red flags should a bank, trader or insurer watch?
Each sign below comes from regulator or UN guidance and is a reason for enhanced due diligence on the ship and the deal.
- Particulars that do not fit the IMO record. A different type, tonnage or year of build is the mark of an identity swap.
- AIS that does not match the papers. A broadcast name or number unlike the documents points to spoofing.
- Several names or flags in a short period. OFSI calls flag hopping common and mostly legitimate, so judge the frequency and the new flag.
- A flag the registry cannot confirm, or one kept after deregistration; OFSI and the 2020 advisory ask firms to report both.
- A new owner or manager just before the voyage. The UN Panel saw registered ownership change before sanctioned trade.
- Ship to ship transfers at night or with AIS off. IMO resolution A.1192(33) of 6 December 2023 lists switching off AIS and concealing a ship's identity among dark fleet behaviors.
- Insurance from an unproven provider. The Price Cap Coalition warns of unproven protection and indemnity insurers in the shadow trade.
- Papers that do not fit the cargo or route. They can also point to trade based money laundering.
How does screening catch a laundered identity?
Each technique in Table 1 fails a different check. A search on the IMO number and every former name finds renamed and reflagged ships. A borrowed number passes it. Matching the ship's particulars to its record catches that, and AIS history from a data provider shows gaps and borrowed broadcasts. Owners come next, and everyone is screened again when the ship, flag or owner changes.
Picture an illustrative charter request for a crude oil tanker built in 2004, about 105,000 deadweight tons. Its IMO number is on no list. The record for that number describes a product tanker built in 1998 of about 40,000 tons. Name and flag match; type, year of build and tonnage do not. Three failed fields out of five point to another hull. The file goes to an analyst, who asks for the certificate of registry and confirms the flag with the registry before anyone quotes a rate.
The free check covers the first step only, since it reads sanctions lists. In a payment, payment screening screens both parties through the API as the transfer runs, but a ship named only in the reference field still needs its own IMO search.
Back to IMO 9304667. The hull went from ADISA under Panama to the Skipper under a false Guyanese flag, and on 27 February 2026 the Justice Department announced a civil forfeiture complaint against it, which it notes is an allegation. A search of the 28 October 2026 SDN file for Skipper returns nothing. A search for 9304667 returns ADISA.
How this page was checked. Minhac Celik wrote the page. Ufuk Gürdaş, Compliance Specialist, reviewed it. The shared IMO numbers, names and flags were recounted on 1 November 2026 from OFAC's SDN and alias files (28 October 2026) and the UK Sanctions List file (30 October 2026); other facts link to their sources.
