Businesses can assess sanctions and shipping disruption risks by mapping who and what is involved in critical supply chains, checking applicable sanctions rules, identifying transport dependencies, ranking the resulting risks, and preparing actions for before, during, and after a disruption. The assessment must reflect the company’s jurisdictions and the actual parties, goods, services, routes, and payments involved; general guidance cannot determine a particular company’s legal obligations.
What should a supply-chain risk assessment cover?
Look beyond the direct supplier and the physical shipment. A useful map connects the business relationships, goods, movement, and money involved in critical flows. Include the company’s relevant group entities as well as external parties, and note where visibility is incomplete.
- Parties: Direct and indirect suppliers, customers, intermediaries, end users, beneficial owners, and people or entities with control.
- Goods and use: Product descriptions and classifications, origin, restrictions, and the stated end use.
- Movement: Transport route, port calls, carriers, freight forwarders, customs processes, warehouses, and inland connections.
- Services and funds: Insurers and other shipping services, financing, and the payment path, including any intermediaries.
- Concentration and visibility: Inputs with few substitutes, single-port or corridor dependencies, and links the business cannot reliably verify.
Ports depend on coordination among freight forwarders, carriers, shippers, customs, inland logistics, warehouses, and other port actors. A problem in one part of that chain can affect the rest, so the map should show connections rather than treat a port as an isolated hand-off. UNCTAD’s port resilience guidebook describes these interdependencies.
Which sanctions rules might apply?
Start by establishing the company’s legal and operational reach. Record where the company and relevant group entities operate; where staff, counterparties, and end users are located; and where goods, services, financing, insurance, and payments pass. Then identify the sanctions regimes and trade controls that may govern each activity. Do not assume that one country’s rules apply universally—or that a business outside that country can ignore operational exposure connected to it.
UK guidance for non-UK businesses notes that UK-linked banks, suppliers, insurers, or shippers may be unable to resolve sanctions concerns, with serious operational and commercial consequences. It also notes that third-country national laws can regulate overlapping activity. The European Commission’s due-diligence guidance separately focuses on export-related sanctions. Both are useful starting points, not a substitute for determining which rules apply to the company’s facts. See the UK guidance for non-UK businesses and the European Commission’s due-diligence guidance.
Because sanctions and official designations can change, check current rules and lists when assessing a transaction and set triggers for checking again. As of 28 January 2026, the UK Sanctions List became the only source for UK sanctions designations after the Consolidated List closed. Businesses assessing UK exposure should consult the current official list and applicable rules, rather than rely on an archived list or a prior screening result. The UK maritime financial sanctions guidance explains the list change; the government’s starter guide to UK sanctions provides an overview of UK sanctions.
How do you check whether a supplier or shipment creates sanctions risk?
Screen the relevant parties and identifying details against the official lists and rules for the jurisdictions that may apply. Consider ownership and control, not just the name on an invoice: an entity’s status may be affected by who owns or controls it. For a shipment, connect that screening to what the goods are, who will use them, how they are described, and how they will move and be paid for. UK guidance describes screening and repeat checks over time; the UK maritime guidance and guidance for non-UK businesses are relevant references.
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Check whether transaction details make commercial sense. For example, ask whether the supporting documents identify the actual end user, the stated end use is clear, the commodity code and goods restrictions are understood, the route is plausible for the trade, and the payment pattern fits the buyer and product. Maritime-industry guidance from the UK and US also discusses risk indicators and due diligence: see UK OFSI’s financial sanctions guidance for maritime shipping and US OFAC’s maritime shipping compliance guidance.
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Red flags are reasons to investigate, not proof of a breach
- Circuitous or otherwise unexplained routing.
- End-use records that conflict with one another or do not identify the actual end user.
- Falsely declared origin or commodity codes, or goods inconsistent with the buyer’s ordinary business.
- Opaque intermediaries or shell companies that obscure ownership or control.
- Unexplained, last-minute changes to payment routing.
Any of these may warrant a pause, document review, escalation, and specialist advice. None, on its own, establishes a sanctions violation or deliberate evasion. Record what prompted the review, what was checked, and how the concern was resolved.
How do you assess a key route or port’s disruption risk?
For each critical flow, identify the ports, canals, straits, carriers, transport services, and inland links it depends on. Consider relevant hazards, including geopolitical conflict, sanctions restrictions, congestion, severe weather, infrastructure failure, labor disruption, and cyber incidents. Assess both the chance of disruption and its severity for the business, including indirect effects that could propagate through the transport chain.
For each dependency, estimate what a switch would involve: whether an alternate route, port, carrier, mode, or supplier is feasible, how quickly it could be used, and what it would cost. UNCTAD’s port-risk method frames assessment around the probability and severity of hazards and the impacts across the transport chain. Its port vulnerability and impact assessment offers a practical reference.
Use global shipping figures as context, not a lane forecast
UNCTAD’s 2025 Review of Maritime Transport reported that vessel ton-miles grew 5.9% in 2024, attributing the growth to rerouting; by May 2025, Suez Canal tonnage was 70% below 2023 levels. It also reported that, from December 2023 to March 2024, average port waiting times increased 23% to 6.4 hours in developed economies and 7% to 10.9 hours in developing economies. These are global or economy-group measures, not forecasts of delay, cost, or disruption probability for a particular shipment or port. The same review says rerouting increased delays, costs, and emissions, while freight-rate conditions remained volatile.
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Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.How should a business rank its risks and compare alternatives?
Rank risks using the business’s own exposure and operating data. Consider potential business impact, likelihood, ability to detect a problem in time, and the company’s ability to prevent or control it. A material sanctions concern may require legal or compliance escalation even if a shipment could be rerouted; a transport bottleneck may demand continuity planning even where no sanctions issue exists. There is no universal risk-score threshold, probability cutoff, or stock buffer established for every business.
When comparing mitigation choices—such as an alternate supplier, port, route, or transport mode—use consistent criteria rather than comparing freight price alone:
| Assessment axis | Questions to ask |
|---|---|
| Sanctions permissibility and jurisdiction | Could the alternative introduce different parties, services, destinations, or legal exposure? Can relevant ownership, goods, and transaction details be verified? |
| Delivery time and reliability | What is the expected delivery performance in normal conditions, and how might it change under the disruption scenarios that matter? |
| Total cost | What are the combined freight, insurance, inventory, and switching costs—not just the quoted transport charge? |
| Substitutability and concentration | Does the alternative genuinely reduce reliance on a single supplier, port, corridor, or service, or simply move the bottleneck? |
| Visibility and verification | Can the business check counterparties, goods, end use, and route well enough to manage the relevant risks? |
| Recovery and feasibility | How quickly could the option work in practice, and what operational changes would be needed to use it? |
These are decision criteria, not a ranking of particular providers or routes. Test them against scenarios that reflect the business’s critical flows and constraints.
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What actions should be planned before, during, and after disruption?
Before an event
- Monitor relevant sanctions lists and rules, route and port status, carrier information, and unusual trade-pattern changes.
- Build disruption scenarios for critical flows and identify feasible alternate suppliers, ports, routes, transport modes, or inventory decisions.
- Agree in advance who can pause a transaction, escalate a sanctions concern, approve an operational switch, and communicate with affected parties.
During an event
- Use clear escalation and response protocols; assess both the immediate transport problem and any sanctions implications of proposed changes.
- Coordinate communications with suppliers, logistics partners, customers, insurers, and relevant authorities as appropriate.
- Document decisions and confirm that a substitute route, party, service, or payment arrangement has been checked before it is used.
After an event
- Assess losses and delays and restore critical flows in a controlled order.
- Review what happened, which assumptions held, and where visibility or contingency options proved inadequate.
- Update risk assessments and response plans to reflect the event and any resulting changes in the chain.
UNCTAD organizes port resilience measures around action before, during, and after disruption. Its port guidebook and 2024 maritime overview emphasize resilience, contingency planning, and proactive action.
When should the assessment be refreshed?
Use both scheduled reviews and event-driven checks. Revisit an assessment when a sanctions rule or list changes; a counterparty, owner, or director changes; a product, service, route, or payment path changes; transaction patterns become unusual; or a material disruption occurs. UK guidance recommends repeated due diligence, audits, staff training, and post-transaction review. Keep records of screening, the risk decision and its reasoning, escalations, any licenses or exceptions relied on, and control testing. A documented trail helps teams understand why a transaction proceeded, changed, or stopped.
Sanctions decisions depend on current rules and specific facts about jurisdictions, parties, ownership, goods, services, routes, and payments. A general process can help a company identify questions and controls; it cannot replace jurisdiction-specific legal advice on a particular transaction.
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