by Lloyd's List
20 September 2024 (Lloyd's List) - COMPLIANCE managers stretched thin by the rapidly evolving sanctions landscape have a new challenge with which to contend — the increasing unreliability of raw Automatic Identification System data in certain conflict zones and high-risk areas because of deliberate global positioning data interference, or GPS jamming.
The interference with GPS signals, intentional or otherwise, is not a new phenomenon and the subsequent impact to AIS data has been widely reported.
What is new is the prolonged severe disruption of positional data in conflict zones. This includes what compliance professionals would deem high-risk areas, making it impossible to ascertain vessel movements over critical periods of time.
Unusable AIS data is a concerning development for industry professionals that rely on vessel-tracking data for compliance reviews.
Basic due diligence to determine whether a vessel or company is sanctioned does not cut it in the maritime industry.
Ships not directly sanctioned or owned by non-sanctioned companies can still engage in sanctions evasion or other riskier trades with which shipowners would not want to be associated.
“AIS analysis is very important and just shy of crucial really to have full confidence that a vessel is not engaged in things such as sanctions evasion,” said Control Risks director Cormac Mc Garry.
The price and availability of AIS data makes it the primary tool for many industry professionals to independently verify port calls, vessel voyages and ship-to-ship transfers.
The growing prevalence of erroneous data in place of legitimate vessel positions risks rendering raw AIS data unusable in certain areas during specific periods.
“If it [GPS jamming] becomes so widespread then we may lose our ability to use open source tools to investigate. It’s as simple as that,” warned Mc Garry.
The Black Sea is a prime example of what many would consider a high-risk area where GPS jamming has significantly limited the usefulness of AIS data.
On average, 164 cargo-carrying vessels per day were engaged in Russian trade had their AIS disrupted, according to Lloyd’s List Intelligence data. That’s more than 1,000 vessels throughout the month.
The interference is sometimes fleeting, but a vessel’s positional data is increasingly being compromised for several days.
The AIS trace of two vessels that had been signalling a Russian port as their destination when their AIS data was disrupted is shown in the graphic below.
In both cases of the Panama-flagged panamax bulker AC Youth (IMO: 9401506) and Panama-flagged suezmax Katiuska (IMO: 9236004) the disruption lasted nearly a week. This effectively obscured when and where they loaded cargo.
Any disruption or disablement of AIS data involving a ship engaged in Russian trade would naturally incentivise more due diligence checks.
“If you don’t know where a ship is this is a direct compliance issue because fundamentally, we don’t know what the ship is doing,” said Bosphorus Observer geopolitical consultant Yörük Işik.
Compliance professionals have to be wary of potential ship-to-ship transfers with Russia’s sanctioned ships — which are known to be active in the Black Sea and the Sea of Azov, the shipment of directly sanctioned cargoes, as well as the possibility of a vessel facilitating trade out of occupied ports.
The type of disruption displayed by AC Youth and Katiuska is becoming so common that the presence of abnormal AIS data could lose its power as a “red flag” indicator.
Even if the area is high-risk, if all data is being wiped out for all vessels in a certain place at a certain time, there is no way to draw a conclusion of potentially deceptive behaviour without further corroborating information, which may be hard to come by.
It could mean voyages that are legitimately illicit or suspicious being written off as false positives.
In the Black Sea there is a large blackout of AIS data in the area around the Kerch Strait, which is home to two active STS zones where oil and grain is exported, as well as several ports.
Other areas where data is being tampered with regularly is around the port of Novorossiysk, which impacts vessels arriving and departing the port, as well as in the middle of the Black Sea and further north in the Sea of Azov.
Another element of GPS jamming that complicates the compliance picture is how these instances of disruption vessels are the victims, rather than the perpetrators, which is distinctly different from first-party spoofing where a ship manipulates its own location data.
“We find the GPS jamming issue puzzling because there is nothing that a ship or shipowner can do about it since the interference is coming from elsewhere, and in the Black Sea that is usually military or government forces,” said a compliance professional who preferred not to be named.
The issue of GPS jamming is not limited to the Black Sea.
Vessels sailing in the north of the Red Sea, off the coast of Sudan and the eastern Mediterranean are all regularly having AIS data overridden with illegitimate positions, but the severity of the issue variates.
The image below shows several examples of severe disruption in the eastern Mediterranean in mid-August.
What to do if the signal gets jammed
Satellite imagery is the obvious alternative to AIS data but is an imperfect solution due to cost and reliability.
“There is no open source alternative that is as effective as AIS,” said Mc Garry.
“If we’re doing due diligence work on high-value acquisitions or investments it is possible to use source enquiries and the due diligence process overall can provide surety. But this does not work for everyday checks.”
What it comes down to is resources and budget. However, there are parts of the shipping industry that are not only better positioned to deal with the fallout of GPS jamming but remain unconcerned by the issue.
“GPS spoofing hasn’t really come across our radar as a concern in a compliance sense,” said NorthStandard head of external affairs Mike Salthouse.
“It has very real implications for safe navigation and if unreliable or lost presents an enhanced collision and safety risk, but it hasn’t really affected us in terms of whether somebody is breaking the law or not.”
There is other information at hand to investigate if a concern is triggered, with AIS forming just a small component of assessment.
“We use a range of sources to determine whether sanctions are being broken such as local intelligence, verifying port calls using port lists and using other technology like satellite, synthetic aperture radar and then fusing all of this information to really work out whether we’ve been told the truth or not.”
Freddy Furulund, director security and contingency intelligence & operations centre at DNK, echoed the view that GPS jamming had a limited — if any – impact on operations.
“From DNK’s perspective, jammed position data on a DNK insured vessel could cause temporary and minor challenges to our automatic tracking (insurance) systems, or during a contingency if the jammed vessel is in crisis,” explained Furulund.
“But again, only minor challenges and indeed temporary.”
Similarly to those in insurance, the legal industry has a range of resources to draw on in investigations, but Alexander Brandt, sanctions partner at law firm Reed Smith, says having quality AIS data remains an advantage.
Lawyers take a holistic approach when assessing whether a trade is sanctions compliant, reviewing available documentation, such as cargo documents, ownership and the control of the entities involved, as well the vessel involved and its trading history.
“Per regulator guidance, the assessment of the vessel will focus on flag hopping, properly capitalised insurance, age, ownership, STS transfer history and her AIS trace,” explains Brandt.
“Gaps in AIS coverage and/or manipulation of AIS are obviously a concern and may be an indicator of nefarious activity. I would agree that when it comes to reliable AIS data, more is more and is a key point of consideration.”
AIS has been used both by the regulators and in the context of arbitrations, when assessing sanctions compliance and associated rights and obligations under shipping contracts, he added.
The puzzling predicament that is GPS jamming
GPS jammers are a relatively simple and cheap method to cause disruption because GPS signals are fairly weak.
When jamming takes place a GPS jammer emits radio signals or a signal noise at the same frequency as the signal of the GPS device. This overrides or distorts the signals from the GPS satellites and renders the GPS device unable to calculate its positions, thereby skewing AIS location data.
The weaknesses of AIS data have been discussed at the International Maritime Organization level within the subcommittee on navigation, communications and search and rescue with a focus on deliberate first-party AIS manipulation.
“It [AIS] was designed to be a multi-purpose navigational aid with no provisions for security, since at the time there were no requirements for it,” said the NCSR in a session document from March.
The same document stated: “AIS position information and MMSI can be easily manipulated and spoofed.”
Any service provider that relies on AIS positions will face the same challenges with regards to the manipulation and interference with AIS.
“The fact that AIS data is not as secure as should be is well known among the industry, which means challenges like jamming and spoofing will continue,” said LLI data scientist Thomas Spriggs.
“What we need to do is ensure that people have the knowledge to spot anomalies in AIS, be that spoofing or jamming, versus normal maritime AIS movements.”
Like spoofing, GPS jamming is constantly evolving making it important to monitor and address new trends as they arise.
“Emerging issues include differentiating jamming from spoofing, as circular patterns in AIS location data are seen in both instances, and differentiating legitimate positions from jamming in situations where the jammed position is actually over water and not land,” said Spriggs.
Similar to compliance professionals, one of the main concerns for AIS services providers is being able to provide the narrative of the ship’s likely actions during the time its AIS is impacted.
LLI senior data analyst Paul Copperwheat explains the importance of leveraging human intelligence to verify and validate data and information impacted by GPS jamming.
Manual reviews of vessel positions in areas of known GPS jamming are undertaken to understand the voyage of the ship during the period of interruption.
“Due to the nature of GPS jamming in some cases port calls may have been missed because the positions are jammed while the vessel is berthing,” said Copperwheat.
“In these cases, we review all the data around the time period and can often confirm if the vessel called at the expected port via the Lloyd’s Agency Network based around the world.”
The issue of GPS jamming on AIS data goes beyond potentially jeopardising compliance investigations and presents a problem for the entire industry given the associated safety risks.
Addressing the issue at an industry level is a tricky task given that it is a third-party that is responsible, and the jamming is often deployed for reasons completely unrelated to commercial maritime trade.
“In the Black Sea, this is a Russian defence operation against Ukraine’s successful maritime attacks against Russia’s navy and naval ports,” explains Işik.
“While it ends up impacting all the devices that rely on GPS in the area, this is just a secondary fallout.”
