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Risk & Compliance Methodology

Everything you need to know about on R&C

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Written by Vasilis Kontas
Updated this week

Risk & Compliance Methodology

In this user guide, we explain how our Risk & Compliance solution works, giving you a clear understanding of how we designed it and what data we integrate.

Compliance Tab

In the Compliance tab, you can access the full set of compliance intelligence and risk events associated with the vessel, enabling a comprehensive 360° risk assessment.

We use a color-coded system to help you quickly understand the level of compliance risk:

  • Sanctioned (): The vessel is associated with known sanction risks or has been subject to Port State Control bans and has a red icon with an X inside

  • Risks detected (): Some risks detected and further due diligence is required, it has a yellow icon with an exclamation mark inside.

  • No risks (): No risks have been detected for this vessel is the green icon with a check mark inside.

The events are grouped into 4 risk categories:

  • Sanction risks

  • Management risks

  • Operational risks

  • Flag risks (coming soon)


Fleet Coverage

The R&C solution covers the global fleet of IMO vessels. Sanction and Management risks are already available across the full fleet, while Operational risks are currently available for the commodities fleet and will be gradually expanded to include all vessel types.


Data Timeframe

The Compliance tab shows data for the full history available starting from 1st of January 2022.


Data Sources and Updates

To keep our Risk and Compliance (R&C) info accurate and up-to-date, we use four main sources:

  • OFAC List: From the US Treasury Department.

  • OFSI List: From the UK's Office of Financial Sanctions Implementation.

  • EU List: From the European Union.

  • UN List: From the United Nations Security Council.

Update frequency of R&C data:

We update this data daily to make sure you have the latest info on sanctions and compliance.


Sanctioned Vessels

We give you detailed info about whether a vessel is sanctioned or not. We also provide links to the original sources for more info.

Criteria for Status:

  • No risks (): The vessel is not listed as sanctioned and is presented green

  • Sanctioned (): The vessel is listed as sanctioned by one or more sources and is presented red


Sanctioned Cargo

We tell you if a vessel is carrying any sanctioned cargo, like oil from Iran or Syria. We cover different types of cargo and provide details on specific grades:

  • Crude oil/ Condensate

  • CPP

  • DPP

  • Chem/Bio

  • LNG

  • NGL

  • DRY

Crude oil/ Condensate

All Iranian and Venezuelan grades as sanctioned ().

Russian grades as potential sanctioned cargo ().

We also account for the EOPL (Eastern Outside Port Limit) grade, a synthetic crude grade created by Kpler to identify sanctioned cargoes received offshore Malaysia.

CPP

All exports from Iran (), Venezuela (), Syria () and Russia () are flagged.


DPP

All exports from Iran (), Venezuela (), Syria () and Russia () are flagged.


Chem/Bio

All exports from Iran (), Venezuela () and Russia () carrying Methanol are flagged.


LNG

All exports from Venezuela () and Russia () are flagged.

NGL

All exports from Iran (), Venezuela (), Syria () and Russia () are flagged.

DRY

All exports of Coal, Iron Ore, Steel, Metals and Cement from Russia are flagged ().

This field also captures cases where the vessel has acquired sanctioned cargo via an STS event to allow for end to end compliance monitoring.

Additionally, to provide more clarity to our customers, we have added the HS codes of the sanctioned cargos.

In order to make decisions based on facts, all estimations or algorithm based forecasts are excluded. Under this field you will find information about delivered and in transit trades.

Criteria for Status:

  • No risks (): The vessel has not transported sanctioned cargo

  • Sanctioned (): The vessel has transported sanctioned cargo

  • Risks detected (): The vessel has transported potential sanctioned cargo

To support user understanding of the Sanctioned Cargo risk category, the following list provides the standardized cargo names used within the Risk & Compliance solution.

Cargo list

  • Alcohol

  • Aluminium

  • Ammonia

  • Aromatics

  • Bitumen/Asphalt

  • Blending Comps

  • Butadiene

  • Butane

  • Calcined Petcoke

  • CBFS (Carbon Black Feedstock)

  • Chrome

  • Clean Condensate

  • Coke

  • Condensate

  • Copper

  • Crude

  • Cutter Stock

  • Diesel

  • Dirty Feedstocks

  • Ethylene

  • FO (Fuel Oil)

  • Gasoil

  • Gasoline

  • Glycols

  • Green Petcoke

  • Inorganic Chemicals

  • Intermediate Iron Products

  • Intermediates

  • Iron Ore Concentrate

  • Iron Ore Fines

  • Iron Ore Lump

  • Iron Ore Pellets

  • Jet

  • Kerosene

  • Lng

  • Lubricants

  • Manganese

  • Metallurgical

  • Naphtha

  • Nickel

  • Nitrogen Fertilizers

  • Other Oils and Fats

  • Propane

  • Propylene

  • Scrap

  • Solvent

  • Specialities

  • SRFO (Straight Run Fuel Oil)

  • Steel Bars/Billets

  • Steel Coils

  • Steel Pipes

  • Steel Plate

  • Steel Rods

  • Steel Slab

  • Thermal

  • Tin

  • Vegoils


Sanctioned Trade

This field captures trades that are restricted by sanctioned programs and provides critical insights into specific trades affected by international sanctions.

We detect exports from Iran, Syria, Russia, and Venezuela and map these trades to the EU, US, UK, and to G7 countries. For each detected trade, we provide details such as the cargo being shipped, the dates of the trade, and links to the official sanctioned programs.

Criteria for Status:

  • No risks (): The vessel has not been involved in sanctioned trade

  • Sanctioned (): The vessel has been involved in sanctioned trade

  • Risks detected (): The vessel has been involved in trade that could potentially be sanctioned


Sanctioned Ownership

In addition to assessing vessel and cargo sanctions, we also scrutinize the ownership structure to determine if any layer of ownership is subject to sanctions. Our analysis covers these six layers of ownership:

  • Beneficial Owner

  • Registered Owner

  • Commercial Manager/Disponent Owner

  • Operator/Charterer

  • Technical Manager

  • ISM Manager

We review each layer against sanction lists to identify any matches. If any layer of ownership is found to be listed in the sanction lists, we flag the vessel accordingly, adding another dimension to our compliance assessment.

Criteria for Status:

  • No risks (): The vessel's ownership is not subject to sanctions

  • Sanctioned (): The vessel's ownership is subject to sanctions


Sanctioned Flag

We assess whether the vessel's current and past flags are associated with a sanctioned program, providing insights into potential risks.

Criteria for Status:

  • No risks (): The vessel’s flag is not associated with any sanction program

  • Risks detected (): The vessel’s flag is associated with a sanction program


Classification society, P&I club & ISM manager

We provide information about a vessel's Classification Society, P&I Club, and ISM Manager, which helps you understand who are the associated companies linked to a vessel and responsible for its insurance and adherence to safety standards.

Additionally, we have incorporated IACS and IG P&I Club information alongside the names of the Classification Society and P&I Club to further enhance the vessel screening process, providing an additional indication that the vessel meets the international standards and has proper insurance coverage.

However, in cases where this information isn't known, we flag it to highlight potential risks since this information should in principle be easily accessible.

Criteria for Status:

  • No risks (): Classification society, P&I club and ISM manager are known.

  • Risks detected (): Classification society, P&I club and ISM manager are unknown.


Port State Control Data

In this section, we delve into the critical aspects of port state control (PSC), where ships are inspected in ports to verify that the condition of the ship and its equipment comply with the requirements of international regulations and that the ship is manned and operated in compliance with these rules. Our data sources rely on the Paris, Tokyo, Mediterranean, Black Sea, Caribbean, Indian, Abuja and United States Cost Guard (USCG) Memoranda of Understanding (MoUs), which provide valuable insights into vessel inspections, detentions, and bans.

Inspections

When assessing a vessel’s compliance, it’s essential to consider recent inspections. Users can access details such as:

  • Type of Inspection: Whether it was a routine inspection, targeted inspection, or other specific checks.

  • Port of Inspection: The location where the inspection took place.

  • Deficiencies Detected: The number of deficiencies identified during the inspection.

Detentions

Detentions occur when a vessel fails to meet safety or environmental standards. Key information related to detentions includes:

  • Date of Detention: When the vessel was officially detained.

  • Duration: How long the detention lasted.

  • Port of Detention: The specific port where the detention occurred.

  • Detainable Deficiencies: The number of deficiencies categorised as detainable.

Bans

Vessel bans are serious consequences that impact a ship’s operations. If a vessel has been subject to bans, users can find the following details:

  • Duration of Ban: How long the ban remains in effect.

  • Reason for Imposition: The specific reasons that led to the ban.

Criteria for Status

  • No risks (): No detentions and bans detected for the vessel.

  • Risks detected (): Detentions detected but no bans.

  • High risk (): Bans detected.

We regularly update this information to maintain accuracy and relevance. By staying informed, you can make informed decisions regarding vessel compliance and mitigate associated risks.


High risk AIS gaps

The objective of this feature is to identify and analyze Automatic Identification System (AIS) gaps to detect potential security and compliance issues.

To achieve this, we continuously collect AIS data from our global AIS network for all vessels transmitting on AIS. An AIS gap is detected if there is no AIS signal from a vessel for more than 20 hours since the last received AIS position.

We then evaluate the AIS coverage in the area where the ship was last reported and assess the AIS coverage based on the vessel's projected position during the AIS gap. This helps us determine the nature of the AIS gap.

Qualification

  • If the AIS gap is due to an AIS network coverage issue this is qualified as a low-risk AIS gap and will not be shown on the Kpler terminal.

  • If the AIS gap is not due to an AIS network coverage issue, this can potentially indicate that the AIS transponder onboard the vessel has been deliberately switched off. The AIS gap will be qualified as a high risk AIS gap.

The High risk AIS gaps table provides detailed information on each event within the selected timeframe, including details such as the the date, location and any detected draught change. These high-risk AIS gaps will be shown as amber risk ().

  • No risks (): No high risk AIS gaps detected for the vessel.

  • Risks detected (): High risk AIS gaps detected for the vessel.


High risk STS transfers

In this field, we provide information which allow you to monitor and assess ship-to-ship (STS) transfers for potential sanction risks.

To achieve this, we track STS transfer activities using AIS data and other market sources. This continuous monitoring allows us to identify when and where STS transfers occur while ensuring that bunkering events are excluded as well.

For an STS transfer event to be considered high risk, at least one of the two vessels involved must meet one of the following criteria:

  • The vessel is sanctioned.

  • The vessel is transferring sanctioned cargo.

  • The owners of the vessel are sanctioned.

The High risk STS transfers table provides detailed information on each event within the selected timeframe, including:

  • Date: The date of the STS transfer (dd/mm/yyyy).

  • Time: The start and end time of the STS transfer.

  • Vessel: Information about the second vessel involved in the STS transfer such as name, IMO and a sanction indication () if applicable.

  • Zone: The Zone of the STS transfer

  • Reasoning: The reason for flagging the event as high risk

Criteria for Status:

  • No risks (): No high risk STS transfers detected within the selected time period.

  • Risks detected (): High risk STS transfers detected within the selected time period.


Dark STS transfers

This field provides verified information about ship-to-ship (STS) transfers that occur while a vessel's AIS transponder is turned off. Every Dark STS event is confirmed using satellite imagery.

Such events present significant compliance and operational risks. By identifying and verifying them, you stay ahead of potential regulatory and sanctions violations and obtain crucial insights for your risk management processes.

The Dark STS transfers table provides detailed information on each event within the selected timeframe, including:

  • Date: The date of the STS transfer (dd/mm/yyyy).

  • Time: The time of the STS transfer.

  • Vessel: Information about the second vessel involved in the STS transfer such as name and IMO

  • Zone: The Zone of the STS transfer

  • Source: The source of event detection

    • Algorithm: Verified via satellite imagery and AIS data processed by our algorithms.

    • Analyst: Verified via satellite imagery and AIS data analyzed by our team of experts.

Criteria for Status:

  • No risks (): No Dark STS transfers detected within the selected time period.

  • Risks detected (): Dark STS transfers detected within the selected time period.


High risk port calls

In this section, we identify port calls to countries under sanctions and provide detailed event data for thorough analysis.

For a port call to be considered high risk, the port needs to be located in Iran, Syria, North Korea, Cuba, Venezuela and Russian occupied Ukrainian territory.

The High risk port calls table provides detailed information on each event within the selected timeframe, including:

  • Date: The date of the port call (dd/mm/yyyy).

  • Time: The start and end time of the port call.

  • Port: The name of the port visited.

  • Country: The country of the port, with an indication () denoting its sanctioned status.

  • Volume: The amount of cargo loaded/discharged during the port call.

Criteria for Status:

  • No risks (): No high risk port calls detected within the selected time period.

  • Risks detected (): Port calls to high risk countries detected within the selected time period.


AIS Spoofing

This field provides the list of intentional AIS transmission falsification from vessels, also known as AIS spoofing. To detect AIS spoofing we use a structured methodology:

  1. Predict vessel position: We forecast the vessel’s next position based on its current movement data.

  2. Compare positions: We compare the predicted position with the actual AIS-reported position.

  3. Identify discrepancies: Significant differences between these positions indicate potential AIS spoofing.

  4. Flag suspicious vessels: Vessels with discrepancies are automatically flagged as suspicious.

  5. Generate reports: We compile a report listing these detected AIS spoofing events, including the dates on which they occurred.

This process ensures accurate detection and reporting of AIS transmission falsification.

The methodology currently covers Tankers.

The AIS spoofing table provides detailed information on each event within the selected timeframe, including:

  • Date: The start and end date of the AIS spoofing (dd/mm/yyyy).

  • Time: The start and end time of the AIS spoofing.

  • Zone: The geographical zone where the event took place.

Criteria for Status:

  • No risks (): No AIS spoofing events detected within the selected time period.

  • Risks detected (): AIS spoofing events detected within the selected time period.

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