Marine Cargo Sanctions Screening Checklist

Purpose

Reusable underwriting and claims checklist for sanctions-aware marine cargo insurance triage. Use with [[2026-06-09]] daily learning note.

Bottom line

Sanctions screening is not a one-time name check. In marine cargo it is a continuing underwriting control over who is insured, what is shipped, which vessel carries it, which ports/routes are used, which banks/payees are involved, and whether the insurer can lawfully bind, collect premium, issue certificates, pay claims, provide GA/salvage security, or pursue recovery.

Minimum intake facts

• Insured / assured / beneficiary / loss payee.
• Shipper, consignee, notify party, freight forwarder, carrier, charterer if known.
• Vessel name and IMO number; flag; owner/operator/manager; prior names if high risk.
• Cargo description, origin, destination, HS code if available, end-use/end-user where risk-sensitive.
• Load, discharge, transshipment, storage, and diversion/substitute port rights.
• Banks, payment currency, premium payer, claim payee, and any letter of credit parties where available.
• Policy/certificate wording: sanctions clause, trade/territorial limits, war/strikes extension, cancellation/termination, claims cooperation.

Referral triggers

• Sanctioned country/region/port/vessel/counterparty nexus.
• Fuzzy match to SDN/consolidated sanctions list, alias, address, vessel IMO, owner, manager, or bank.
• Vessel IMO missing, recent rename/reflag, AIS gaps, ship-to-ship transfer, unusual voyage deviation, or dark-fleet indicators.
• Commodity is oil/petroleum, dual-use, military-adjacent, restricted technology, coal/metals, luxury goods, or other regime-sensitive cargo.
• Open cover declaration lacks vessel/route/counterparty/payment data despite elevated country or commodity risk.
• Request for claim payment, GA guarantee, salvage security, recovery action, return premium, or refund involving sanctions-sensitive parties.
• Non-standard sanctions clause or unclear governing law — 검증 필요.

Decision workflow

1. Separate facts from matches: record exact name/IMO/address/source and whether the hit is exact, fuzzy, alias, ownership/control, or geographic.
2. Check transaction nexus: identify applicable regimes by insurer location, insured/counterparty nationality, currency/banks, route, cargo, and place of performance.
3. Assess performance ability: can the insurer lawfully bind, accept premium, issue certificate, pay claim, issue guarantee/security, or appoint/pay surveyor/lawyer?
4. Escalate unresolved cases: compliance/legal review before bind/payment/guarantee where sanctions status, ownership/control, license, or clause wording is unresolved.
5. Retain evidence: store timestamped screening output, data sources, analyst decision, assumptions, and approval authority.

Coverage / wording questions

• Is the clause framed as exclusion, limitation, illegality/non-performance, cancellation, or condition precedent?
• Does it apply to premium receipt, claims payment, return premium, defence costs, GA/salvage security, sue and labour, and recovery actions?
• Does war/strikes or political risk wording create separate sanctions-sensitive obligations?
• Is there any territory/trade warranty or route restriction independent of sanctions law?
• Does the policy require the insured to provide documents and updated voyage/counterparty information?

AI/DX automation candidate

Build a sanctions-aware declaration triage module that:

• normalizes entity names, vessel IMO, aliases, addresses, and prior vessel names;
• integrates approved sanctions screening tools and stores timestamped evidence;
• flags fuzzy matches, ownership/control uncertainty, high-risk ports/routes, and sensitive commodities;
• maps the issue to underwriting action: quote hold, certificate hold, referral, decline, cancellation review, claim payment hold, or GA/security escalation;
• produces a memo with facts / inference / assumptions / recommendations / 검증 필요 sections.

The module must not autonomously approve bind, claim payment, GA guarantee, or sanctions clearance.

Source pointers

• OFAC — Sanctions Programs and Country Information: https://ofac.treasury.gov/sanctions-programs-and-country-information
• OFAC — Sanctions List Site/Data Formats: https://ofac.treasury.gov/specially-designated-nationals-list-data-formats-data-schemas
• GOV.UK — Financial sanctions regime-specific consolidated lists and releases: https://www.gov.uk/government/collections/financial-sanctions-regime-specific-consolidated-lists-and-releases

Related notes

• [[2026-06-09]]
• [[Russia Oil Price Cap Sanctions Underwriting Checklist]]