CMAR ANNUAL GENERAL MEETING HIGHLIGHTS GROWING IMPORTANCE OF SANCTIONS COMPLIANCE
The CMAR Annual General Meeting brought members together at the Curaçao Maritime Museum for an afternoon of governance, knowledge sharing and networking. During the meeting, members reflected on the association's activities over the past year and discussed several key initiatives, including the Buskabaai project, the successful hosting of the Caribbean Shipping Executives' Conference (CSEC) in Curaçao, and the upcoming renewal of the Memorandum of Understanding (MoU) between CMAR and Curaçao Ports Authority (CPA). The meeting also provided an opportunity to look ahead to the association's plans for the coming year.
One of the key outcomes of the meeting was the reappointment of the current President, Sujit Matoera, who accepted the members' request to continue serving for another twoyear term. The Audit Committee, who had observed the Board's work over the past year was reappointed as well. Their observations and constructive feedback were welcomed and will help guide the Board as it continues strengthening the association.
Following the official meeting, members attended a presentation by Benno van Leeuwen and Marjolaine Jardiner of Compliance & Forensic Caribbean on Sanctions in Practice: Do's & Don'ts. With sanctions playing an increasingly important role in international trade and shipping, the session provided practical insights into how compliance requirements affect maritime businesses.
Using real-life maritime cases, practical examples and audience discussions, the presenters explored topics including sanctions screening, ownership and control structures, dual-use goods, proliferation financing, export controls and sanctions evasion risks within maritime operations.
One of the central messages was that sanctions compliance goes well beyond checking whether a vessel or company appears on a sanctions list. Organizations should also understand who ultimately owns or controls a company or vessel. Even if a vessel itself is not sanctioned, doing business with it may still present risks if its beneficial owner or controlling party is subject to sanctions.
The presentation also highlighted the concept of dual-use goods: products and technologies that serve legitimate civilian purposes but may also have military applications. Depending on the destination, end-user or intended use, transporting such goods may be subject to export controls or additional regulatory requirements.
Throughout the session, participants were encouraged to think beyond simple checklists by asking three fundamental questions before entering into a transaction:
- Who? Can I do business with this person, company or vessel?
- What? Can I import, export, transport or supply these goods?
- How? Could this transaction be used to evade sanctions or export controls?
The presenters also discussed a number of maritime red flags that may warrant additional due diligence. These include complex ownership structures, manipulation of the Automatic Identification System (AIS), unusual trading patterns and operations involving high-risk jurisdictions. While none of these automatically indicate wrongdoing, they may signal that additional investigation is required before proceeding.
An important takeaway was that effective compliance is not about collecting as much information as possible, but about asking the right questions and applying appropriate due diligence. "A clean sanctions screening result does not automatically mean a low sanctions risk. Understand the ownership, the cargo and the voyage—not just the vessel's name" says Benno van Leeuwen. Organizations should request information with a clear purpose and ensure that compliance measures remain proportionate to the risks involved.
The CMAR Board thanksCompliance & Forensic Caribbean for sharing their expertise and all members for their active participation throughout the discussion. Members interested in learning more about sanctions, export controls, proliferation financing or sanctions screening are encouraged to contact Compliance & Forensic Caribbean for further information.
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The Annual General Meeting concluded with an informal networking reception, allowing members to unwind, reconnect and continue conversations in the relaxed atmosphere that has become a valued part of CMAR gatherings.
