UK Offers Guidance to Address Fake Certificates of Origin for Russian Oil Shipments

The U.K. Office of Foreign Sanctions Implementation provided an overview of "red flags" that may indicate when Russian oil shipments have been "manipulated to appear as non-Russian through the use of fabricated or falsified certificates of origin." The guidance also lays out "potential mitigation measures" to help British entities shield themselves from the practice.

The advisory is meant to help industry players conduct due diligence, verify the validity of shipments that have exhibited suspicious activity and conduct spot checks of particular shipments.

The red flags include when the certificate of origin lists a country or outer port limits of a country that doesn't normally produce or export oil or a volume that doesn't correspond with previous oil production metrics, OFSI said. Suspicions also should be raised when a certificate of origin lists a product as being of non-Russian origin but voyage tracking information shows the product initially came from Russia and "no substantial processing of the oil has taken place off the water in a third country."

Other flags include when the certificate of origin "is for a shipment that displays evidence of voyage irregularities," including the manipulation of a ship's automatic identification systems to conduct "suspicious" ship-to-ship transfers while at sea. Inconsistent information between the certificates and attestations, contracts, cargo documents and vessel and voyage details should raise concerns, as should multiple versions of a certificate of origin for a shipment that lists inconsistent information, OFSI said.

OFSI suggested that industry officials and companies verify that the country listed on the certificates actually exports oil, compare the volume of the product listed on the certificate with historical trade data and "risk assess" certifiicates that "appear incomplete, inconsistent, or contradictory to previously shared or publicly available information."

Companies should also ask to see all copies of a certificate of origin if there are red flags and conduct "appropriate due diligence of customers and counterparties" where a "self-certified" certificate of origin has been issued, OFSI said. If concerns are raised, they should contact authorities and audit the relevant documents.