Presentation to the Club des Résidents Etrangers de Monaco (CREM) on "International sanctions in the maritime sector: shipping & yachting"

Legal meetings, 22 September 2026 (Monaco)

Patricia KEMAYOU MENGUE and Paul TOMATIS (Heads of the Banking & Finance, Risks & Compliance AML/CFT-P-C Departments, 99 AVOCATS ASSOCIÉS), in association with Philip ROCHE (Partner, NORTON ROSE FULBRIGHT), and Julien RAYNAUT (Vice-President of Legal & Compliance at Bureau Veritas Marine & Offshore, General Counsel & Compliance Officer, Maritime Arbitrator at the Paris Maritime Arbitration Chamber, and President of the French Maritime Law Association), gave a presentation to members of the Club des Résidents Étrangers de Monaco (CREM) on the topic:

"International sanctions in the maritime sector: shipping & yachting"

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The following points were discussed:

I. Key sanctions regimes

• Complex international system
• Key shipping-related sanctions (main measures affecting the maritime sector: embargo on Russian oil, price cap mechanism, port bans, asset freezes, and restrictions on services (insurance, financing, brokerage, bunkering, maintenance).
• Monaco regime (international instruments and Sovereign Order No. 8.664 of 26 May 2021 on procedures for the freezing of funds and economic resources pursuant to international economic sanctions, as amended (decisions of the Minister of State, consolidated national list maintained by the Budget and Treasury Directorate).

II. Sanctions applied to marine sector

• Best practice: Shipping sanctions guidelines (accurately identifying the vessel (name, IMO number, flag), examining the chain of control (shell companies, beneficial owners), scrutinising the transaction (origin/destination, price, insurance), and documenting each decision).
• Sanctioned activities (including bunkering, maintenance, financing, insurance, brokerage, or assistance to designated vessels or those supplying them).
• Suspicion of illegal activities (red flags: disabled AIS, repeated flag changes, inconsistent documentation, unknown insurance, third-party payments, or routes with no commercial justification).

III. Challenges and reflections

• The challenges of an uniform application of sanctions.
• Monaco specificity.
• Deceptive shipping practices (circumvention practices: ship-to-ship cargo transfers, disabling or manipulating AIS, and opaque ownership structures concealing the origin or price).
• The Dark Fleet, comprising often ageing vessels held through opaque structures, frequently changing flag, and carrying inadequate insurance coverage (threefold risk: economic, legal, and environmental).
• Artificial intelligence as a key support (for vessel verification, beneficial ownership identification, and anticipating circumvention risks).

IV. Conclusion

• Compliance with maritime sanctions depends on precise knowledge of the vessel, its effective chain of control, and the intended transaction.
• For Monaco, the stakes are twofold: preserving the integrity of its financial centre and ensuring that its yachting ecosystem is not used to circumvent sanctions.
• Verify before acting, halt the transaction in case of serious doubt, and promptly notify the competent authorities.