Following renewed attacks on commercial shipping near Yemen, we would like to drawn attention to sanctions compliance and operational maritime safety on the areas of heightened concern.
According to the UKMTO, a vessel transiting the Gulf of Aden, off the coast of Yemen, came under attack on 23 September. The Shipowners’ Club has noted that sanctions compliance and operational maritime safety remain areas of heightened concern. Operators engaging in trade connected to Yemen are strongly advised to exercise extreme caution.
However, decisions regarding the use of armed security, choice of trade routes and other protective measures rest solely with the vessel operator. The recent incidents have involved vessels with outdated or indirect ties to Israel, underscoring the difficulty in identifying potential affiliations. To support risk assessment, a layered approach is recommended, considering factors such as vessel ownership structures and historical port calls to Israel.
Sanctions considerations
Ansarallah involvement: Transactions involving Ansarallah (Houthis) present significant sanctions risk exposure. Particular attention must be given to dealings or transactions with entities owned and controlled (50% or more) by Ansarallah and be treated as high-risk counterparties.
Petroleum products: There are restrictions on the delivery, offloading, or facilitation of petroleum products into Yemen where there is an Ansarallah involvement or port under Ansarallah control. Any Member considering the delivery of cargoes, including refined petroleum products to Yemen is strongly urged to undertake stringent due diligence as to the ownership of the intended port of discharge and the identity of the cargo receiver.
Enhanced due diligence: Ensure comprehensive screening of counterparties, cargoes and trade routes to avoid direct or indirect links with sanctioned parties or restricted goods. Supply chains face heightened scrutiny, with vessels, insurers, and traders exposed to potential secondary sanctions or compliance violations. These risks make financing, shipping, and insurance particularly complex and may bring it within the scope of sanctions.
Vessel and crew safety in the Red Sea
Recent attacks: The Red Sea has witnessed an escalation in hostile activity, including missile and drone attacks and deliberate vessel targeting leading to vessel sinkings. The Joint Maritime Information Centre (JMIC) has reported that a vessel (irrespective of flag or nationality) might be targeted not because of its own actions, but due to its corporate ties or sister vessels’ history. These incidents pose a direct risk to both vessels and crew safety, especially where there is no consistent logic in vessel targeting.
Targeting typologies: Vessels with links to Israel – including through flag, ownership, management, chartering, service provision, or even identifiable trading connections (i.e. historic port calls) – have been subject to heightened risk of attack. The targeting of vessels with links to Israel may come from more than one armed group i.e. the Yemeni Armed Forces and therefore is not limited to the Houthi group.
Western – affiliated vessels: Vessels with identifiable Western ownership or affiliation such as US, UK or EU operators or service providers may also be viewed as potential targets.
Practical implications: A targeted approach may mean that even indirect connections to Israel (for example, a parent company, beneficial owner, or key service provider) could expose vessels to increased operational risk in the Red Sea.
The Shipowners’ Club recommends the following:
- Conduct ongoing robust due diligence on counterparties and cargoes in order to identify and mitigate risks that could elevate targeting risk.
- Carefully review sanctions exposure where Ansarallah are concerned.
- Fully re-assess operational exposure for vessels transiting the Red Sea and implement enhanced and updated risk mitigation measures.
- Carefully assess voyage planning adjustments, transit timing and up to date local guidance (i.e. contact local correspondents) before navigating these waters.
- Contingency planning for crew safety and vessel protection is strongly advised when operating in a high risk/war area.
- Note that vessels with Western service connections or perceived affiliations to Israel have been disproportionately targeted. This includes ships with ownership, management, or service providers linked to Western companies or with identifiable trade routes involving Israel. However, the risk of false targeting still persists.
- Furthermore, it is encouraged to adopt best practice measures as illustrated within the BMP Maritime Security guidance that focuses on risk management processes and addressing global threats.
Operators are encouraged to integrate this guidance into their broader risk assessments and to consider the use of maritime security services, alongside situational awareness tools, to inform navigation decisions in areas of heightened threat.