IMO Legal Committee · Current work
Registration guidelines, the fight against fraudulent registries, and a scoping exercise across the whole IMO rulebook.
Diego Ramirez Chair, IMO Legal Committee Deputy Commissioner of Maritime Affairs, Republic of the Marshall Islands General Manager, Fort Lauderdale Office, Marshall Islands Registry
Introduce yourself briefly; the slide carries the titles.
Frame: three work streams at LEG that add up to a single approach to substandard shipping — and one lesson that runs through all of them.
The problem is rarely a missing rule. It is uneven implementation, weak enforcement and poor information-sharing.
Item 6 is the long-running stream, target completion 2027 at LEG 114. Item 12 produced the Guidelines on the registration of ships, approved at LEG 113 and now folded into item 6. Item 13, the scoping exercise, is with a correspondence group asking which existing IMO instruments can be used better and where the gaps are.
All of it rests on UNCLOS: the sovereign right to register a ship (art. 91) is inseparable from the duty of effective jurisdiction and control (art. 94).
The scoping exercise's central finding (LEG 113/13, para 15): the problem is rarely a missing rule. It is uneven implementation, weak enforcement and poor information-sharing.
Approved at LEG 113 · issued as a Legal Committee circular · non-binding · merchant ships on international voyages
Approved at LEG 113 and issued as a Legal Committee circular, not an Assembly resolution — several delegations care about that distinction.
Scope: merchant ships engaged on international voyages. Non-binding, registry-model neutral, and explicitly no obligations beyond existing conventions.
Especially useful for new and aspiring registries, and for those wanting to improve their procedures.
Member Governments are invited to report back on implementation experience so the Committee can decide on further action.
Ownership: incorporation documents, directors and shareholders, beneficial ownership information, verified powers of attorney.
Deletion: proof of de-registration from the previous flag before permanent registration. A prompt confirmation of deletion, or of consent to transfer, counts as an official communication.
Identity: IMO number, Continuous Synopsis Record (SOLAS XI-1/5), cross-checks in GISIS. Certificates with security features and online verification tools.
Sanctions: screening against the UN Security Council list and relevant national sanctions, before registration and routinely thereafter.
Class and insurance: verified against reputable third parties and other flag States; compulsory insurance accepted only per LEG.1/Circ.16.
After registration: repeated deficiencies or detentions may trigger enhanced monitoring or deletion; deletions notified to the IMO number service provider to curb flag hopping.
| IMO Number | Name | Flag | Gross Tonnage | Type | Year of Build | Registered Owner |
|---|---|---|---|---|---|---|
| IMO 7723273 | ARDALAN | Angola False | 354 | General Cargo Ship | 1978 | HEDAYAT F |
| IMO 9005053 | AXON I | Angola False | 44,868 | LPG Tanker | 1993 | SKIATHOS MARITIME & TRADING SA |
| IMO 9012886 | FOGAS | Angola False | 42,341 | LPG Tanker | 1993 | RPTD SOLD UNDISCLOSED INTEREST |
| IMO 9220952 | QUINN | Angola False | 159,990 | Crude Oil Tanker | 2001 | QUINN SHIPPING LTD |
| IMO 7720374 | ARSIAN | Anguilla False | 489 | General Cargo Ship | 1978 | ZAREIE F |
| IMO 9267950 | SEAGATE | Anguilla False | 7,884 | LPG Tanker | 2003 | CORFU MARITIME & TRADING SA |
| IMO 1029223 | P. I. VICTORIA 2 | Aruba False | 1,986 | Products Tanker | 2006 | PACIFIC ISLAND TRADING INC |
ships currently sailing under a flag they are not entitled to
GISIS false flag module, 15 September 2026
Scale: 561 vessels currently listed as falsely flagged in GISIS, many without valid class. This is the public module — anyone can look it up.
Small States, SIDS and LDCs are targeted most: Tonga reported three fake websites posing as its registry.
Draft Assembly resolution proposed. The registration parts were absorbed into the new Guidelines; the rest — coastal and port State actions, Secretariat actions, technical cooperation — goes to a Working Group at LEG 114.
Tools already in place: registry contact points in GISIS (Circular Letter No.4190), the IMO fraud webpage, and circular letters from victimized States.
Eight thematic areas — registration, insurance, ship identification, port State control, ship-to-ship transfers, AIS/LRIT/VDES, certification, audit schemes — and the IMO organ responsible for each.
Outcome-based, by theme rather than instrument by instrument; a clear line between Legal Committee matters and those for MSC, MEPC, FAL and III. The highlighted tiles are where LEG holds the pen.
Candidate outputs for LEG: a GISIS module on accepted and rejected insurers; guidance on the evidentiary and liability consequences of AIS manipulation; STS transfers on the high seas (MEPC lead); wider use of electronic certificates (FAL lead).
Next: Correspondence Group re-established, free to meet virtually, tasked with drafting terms of reference for a Working Group at LEG 114.
LEG 114: two working groups, one consolidated instrument.
Questions welcome.
Land it: at LEG 114 a working group continues the consolidated guidelines under item 6, and a second working group takes up the scoping exercise. Then open for questions.