Disabling the Automatic Identification System (AIS) on vessels is a well-documented deceptive practice used to evade sanctions. This tactic, often referred to as "going dark," intentionally conceals a vessel's location and voyage data from monitoring systems. Malign actors use this method to engage in prohibited activities, such as illicit ship-to-ship transfers of sanctioned cargo (e.g., oil, coal) or making covert port calls in sanctioned countries. Regulatory bodies, like the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC), explicitly identify AIS manipulation as a primary red flag for potential sanctions evasion and illicit maritime trade.

A. Transshipments are a standard, legitimate logistics practice for transferring cargo between vessels and are not inherently deceptive.

B. Refueling at a port in a prohibited country is a direct sanctions violation itself, rather than a deceptive practice to conceal an activity.

D. Chartering an entire vessel to one client is a common and legitimate commercial arrangement in the shipping industry.

1. U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC). (2020, May 14). Guidance to Address Illicit Shipping and Sanctions Evasion Practices. Section: "Deceptive Shipping Practices," Subsection 1, "Disabling or Manipulating the Automatic Identification System (AIS) on Vessels." This advisory explicitly states, "One of the most common ways bad actors try to hide their illicit conduct is by disabling their AIS transponders."

2. United Nations Security Council. (2021, March 4). Final report of the Panel of Experts established pursuant to resolution 1874 (2009) (Report No. S/2021/216). Paragraphs 65-71. The report details numerous instances of Democratic People’s Republic of Korea (DPRK) vessels disabling their AIS to conduct illicit ship-to-ship transfers of petroleum products and coal, demonstrating it as a core sanctions evasion technique.