Two months ago, I wrote a post about sanctions and this topic
and indicated that I would present a recent example of sanctions at the FPC conference organised by Zanders.
In the meantime, evidence has been provided that something was amiss.
What happened?
May 2025
An observant employee noticed that a large LNG tanker had left the Russian Arctic region with LNG bound for Europe, but soon disappeared from the radar. The tracker went off. It also appeared that in northern Europe, the ship sometimes stopped for a while and then returned empty. There had been a board-to-board transfer. Possibly also to companies in which the observant employee’s employer was involved.
Wasn’t there a sanctions issue here? (Russians involved in LNG could already be on the sanctions list) and this behaviour of the tanker wanting to be invisible was very unusual.
During the lecture, I was critical of all those who see AI and data analysis as the holy grail of compliance. I explained, using this example among others, that I still support the 2021 FATF document stating that IT developments can certainly help us, but that human intervention remains essential.
What is the follow-up to the case:
27 June (Reuters)
- A liquefied natural gas (LNG) vessel called Iris that has been sanctioned by the U.S.
July
Two LNG tankers appear to have made these kinds of unusual voyages.
August
A third comes into the picture.
Then the system is adjusted, and what happens next?
15 September (Reuters)
A fourth tanker carrying liquefied natural gas from Russia’s sanctioned Arctic LNG 2 project discharged its cargo at a Chinese port on 14 September, four days after a third LNG vessel departed, LSEG ship-tracking data showed.
Current situation:
Take a look and you will see similar behaviour with trackers that are switching off, but now only travelling on the eastern side of Russia.
Only with LNG?
As during the lecture, many will not do anything with LNG, but that is not my point. I gave examples of how this could also apply to other goods. But the most important thing is that this employee, with his professional knowledge and by using targeted (in this case MISSING) data, discovered this. IT was supportive, but his professional knowledge of the market and how criminals deceive us was the basis.
If you would like more information, please leave a message.
If there is more demand, I will write a more extensive piece with more detailed information on the site.


