
Are Financial Institutions Now Expected To Scrutinize Vessel Behavior?

I would never have guessed that my maritime shipping and Naval Intelligence background would become helpful in the financial services realm—yet here we are. Let me explain…
“We’re Bankers, Not SEAL Team Six.”
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“We’re bankers, not SEAL Team Six. Are we really expected to start analyzing ship behavior?” This quote from a colleague in a discussion about the idea of Financial Institutions (FIs) monitoring the behavior of ocean-going vessels (ships) motivated me to co-author a white paper on the topic.
Today’s global geopolitical climate is fraught with both nation-states and individual bad actors who use the financial system to conduct their misdeeds. While sanctions can be an effective tool to shut these bad actors out of the financial system, it is far from a panacea. Necessity has become the proverbial mother of invention for bad actors in creating methods to circumvent sanctions and international laws. The typologies range from turning off their safety position reporting to pretending to be a different vessel altogether.
Government GuidanceBigstock
In May 2020, the U.S. Departments of State and Treasury and the U.S. Coast Guard published “Guidance to Address Illicit Shipping and Sanctions Evasion Practices.” The guidance document provides information targeted for specific stakeholders—one of which is Financial Institutions (FIs). This was a seminal moment. For the first time, FIs were mentioned in government guidance on detecting potentially unusual ocean-going vessel behavior.
Governments recognize the challenge of keeping abreast of the methods of evading laws and impose various regulations on private sector stakeholders to detect and deter nefarious activity. The trend has undoubtedly been government regulators requiring more of Financial Institutions (FIs) compliance measures, not less. U.S. regulators are particularly demanding of FIs in this regard. Whether or not the regulations are reasonable is irrelevant. Once imposed, FIs must find ways to comply.
Why Focus On Transportation?Bigstock
The sale of commodities is almost invariably accompanied by the need to transport the goods to their destination. It is this transportation element that regulators have recently turned their attention to. This attention is now buoyed by the need to detect the illicit transfer of bulk commodities, such as Russian oil, in the wake of the invasion of Ukraine.
The complexities of trade finance, global supply chains, and the various roles of FIs in a trade transaction can make this a daunting task. This realization motivated me to co-author a white paper on the topic through the Bankers Association for Finance and Trade (BAFT). The paper published by BAFT in early December 2022 is entitled “Perspectives on Evaluating Potentially Unusual Vessel Behavior.” My maritime shipping experience served me exceptionally well in this endeavor.
Understanding The FundamentalsBigstock
While banks offering trade finance products likely have a working knowledge of shipping documentation, staff may need to become more familiar with the maritime shipping industry details. This can pose challenges when shipments or transactions are flagged as unusual and compliance issues arise. The paper aims to provide bankers with a rudimentary understanding of maritime shipping and the compliance risk associated with this space. It accomplishes its objective by organizing the material in a methodical fashion meant to be read from beginning to end. The paper begins by familiarizing the reader with basic maritime shipping industry jargon and practices. For example, did you know ships have an identification number that never changes (think of your car’s VIN) even after being sold or renamed? It then lists the most common typologies for vessels evading sanctions, ways to evaluate your FI’s inherent risk, and several considerations when developing appropriate controls for your organization.
My co-authors and I spent hours discussing (which at times pivoted to spirited debate) certain portions of the material. We endeavored to strike the right balance for reasonable measures to evaluate vessel behavior for FIs with varying resources available to Financial Crime Compliance departments. I believe the many hours of Zoom call discussions paid off in the form of a handy white paper for FIs in addressing this evolving risk.
To read “Perspectives on Evaluating Potentially Unusual Vessel Behavior,” please visit BAFT’s Library of Documents under BAFT Guidance and Industry Practice section at www.BAFT.org.
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Proactivity, as defined by organizational behavior, is “anticipatory, change-oriented, and self-initiated behavior in situations, rather than just reacting." When a person is proactive, they are acting in advance of a future event. Proactive employees typically don't need to be asked to do something, and will usually require less-detailed instructions.
Proactive behavior is applicable to either one's own role or to "extra role" responsibilities. Within one's own role, for example, a person may find a more efficient way to complete one or more of their responsibilities. Extra role responsibilities (i.e., those tasks outside of your stated job description) speak to an employee's organizational citizenship behavior (OCB). The proactive employee would, for example, initiate an offer to help their co-workers before they are asked to assist by either their colleagues or their manager.
The steps you can take to become more proactive at work apply to both your formal role and your part of the scope of the OCB within your team, your department, and your overall organization.
There are variations on the theme; however, the following behaviors are a common foundation for proactivity within all of the theories:
Organize | Take Stock | Be PositiveBigstock
Proactivity requires that you be organized. That includes your mindset, your space, and, of course, your schedule! Organizing your time helps you approach tasks more efficiently and allows you to be more open to opportunities. This scheduling needs to include "downtime" for those activities that keep your life in balance.
A positive attitude is right up there on any list. Approaching tasks from a positive perspective encourages you to look for the best in every situation. It helps you become the employee who is "ready, willing, and able," who can always be counted on. A team player who is reliable and available will become the go-to person, the problem solver.
Take stock of your current responsibilities:
- What are your tasks?
- What are the priorities?
- What can be consolidated, eliminated, or shortened?
- What can you do to stay ahead of less urgent tasks?
- How do you solve problems?
- Can you prevent problems by planning ahead and developing alternative processes in anticipation?
- What are the things you still need to know?
- Can you automate any of your tasks to make them more effective and less time-consuming?
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Find a role model by observing the leaders in your company. When possible, spend time with them to gain insight from their behaviors. Try out their techniques. Some will work for you, others will not. You'll need to fine-tune what you acquire so that you are able to build your own repertoire.
Let others know that you want to be more involved. You'll need to create your own opportunities. Don't wait to be asked—present your ideas to your management team.
Goals | Persistence | ExcellenceBigstock
Set goals for yourself. Write them down! List everything that you want to accomplish. Set deadlines! Once you have the end in mind, you can achieve your desired outcome. A series of small goals leading up to the completion of a large goal keeps tasks from becoming insurmountable.
Stay the course on how you want to accomplish your goals. This may require overcoming your fears and rising above obstacles or setbacks. You'll need to step outside of your comfort zone and become increasingly resilient.
Strive for excellence from start to finish. Commit yourself to always presenting your best work—your completed project with no loose ends. Be passionate about what you do. Give it your all. No matter what role you are assigned, you will be more effective when you put your full energy and effort into it.
Celebrate! | Be Flexible!Bigstock
Celebrate your successes, big and small, as you move along your path to becoming more proactive!
Be flexible! You can't plan for every outcome, so being able to react to the unexpected is an important trait for the proactive person. It is about the awareness of the existence of choices, regardless of the situation or the context.
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This article was originally published at an earlier date.
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Originally posted on: https://www.workitdaily.com/financial-institutions-analyze-vessel-behavior