U.S. DEPARTMENT OF THE TREASURY
Office of Foreign Assets Control
April 1, 2026
Publication of Sanctions Advisory: Guidance on Identifying “Non-Standard Maritime Silhouettes” and Active Camouflage within the Shadow Fleet
The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC), in coordination with the U.S. Department of State and the U.S. Coast Guard, is issuing this advisory to alert the maritime industry to “Visual Signal Obfuscation” (VSO) tactics currently employed by the Shadow Fleet to circumvent the G7+ Price Cap and avoid detection in high-traffic corridors.
As outlined in Executive Order 14501, “Addressing Extra-Territorial Maritime Deception,” U.S. persons are advised that the use of “Trompe-l’œil” hull painting, inflatable superstructure extensions, and “active-chameleon” heat-shielding technology constitutes a significant evasion risk.
Regulatory Concerns: The “Iceberg” and “Megayacht” Protocols
OFAC has identified a trend where sanctioned crude oil tankers are undergoing structural modifications to appear as non-sanctioned vessel types when viewed from satellite or aerial surveillance. Recent findings include:
- Pseudo-Leisure Conversions: Tankers utilizing magnetic “hull-wraps” to mimic the visual signature of luxury pleasure craft or research vessels.
- Active Camouflage (AC): The application of light-refractive coatings that cause the vessel to blend into sea-state patterns or, in Arctic routes, mimic the geometric profile of large icebergs.
- Bio-Mimicry Signatures: The deployment of acoustic decoys that broadcast the frequency of migratory whale pods to confuse sonar-based tracking systems.
Compliance Expectations
Marine insurers, port authorities, and bunkering services are expected to conduct “Optical Due Diligence.” If a vessel’s length-to-beam ratio appears to “shimmer” or fluctuate during daylight hours, it must be flagged as a “Potential Visual Evasion Event” (PVEE).
And a new General License:
And a new Frequently Asked Question:
Frequently Asked Question (FAQ) 1401
Q: My satellite imagery shows a tanker that looks like a giant floating rubber duck. Is this a sanctioned vessel?
A: Possibly. Under the “Strict Liability” standard, the internal cargo (crude oil) determines the sanctions status, regardless of whether the external hull is yellow, buoyant, or has a beak. OFAC recommends that you do not “squeeze” the duck until you have verified the Ultimate Beneficial Owner (UBO) via the hotline at 1-800-APR-FOOL.
oh, and one more thing, in case it wasn’t clear…
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