The Mongolian government said it has delisted 14 North Korean vessels registered in the country, following the passage of the UN’s most recent resolution passed in March.

Reporting to the UN about progress on implementation of the new sanctions, Mongolia said the DPRK ships could no longer sail under its flag.

In the maritime industry, the practice is known as using a “flag of convenience” (FOC), a system which allows companies to register vessels in other countries. Despite being landlocked, there are currently over 400 ships sailing with Mongolian flags.

“There had been some DPRK vessels carrying the Mongolian flag before resolution 2270 was adopted. Upon the instruction of the Ministry of Road and Transport of Mongolia, 14 vessels were de-registered and their contracts terminated,” the Mongolian implementation report reads, before adding there are no longer any North Korean ships sailing with Mongolian flags.

Under the new measures, the UN Member States which allow foreign vessels to use their flags can no longer do so for those administered by DPRK entities. North Korea is suspected of using FOCs and exploiting maritime loopholes to hide its involvement with a large number of vessels.

14 vessels were de-registered and their contracts terminated

The DPRK’s shady practices led the UN, the U.S., South Korea and Japan to take specific action on North Korean shipping. All UN member states should now refuse entry to a list of 27 vessels, while also prohibiting the use of North Korean crew or ship chartering services.

The new sanctions call “upon the Member States to de-register any vessel that is owned, operated or crewed by the DPRK,” paragraph 19 of Resolution 2270 reads.

TESTING THE WATERS

Mongolia’s report did not include a list of which vessels were struck off its register, but the business of reflagging ships usually triggers changes across numerous maritime databases.

With data provided by ship tracking site Marine Traffic, NK News analysis discovered 25 ships have changed from a Mongolian flag since Resolution 2270’s passage in March.

Eight of the total were large oil tankers owned by Iranian organisations with no ties to North Korea (though themselves no strangers to maritime sanctions). Of the remainder, several had changed back to registries in their home countries, which are not open to foreign organizations, a measure that would prevent North Korea from using their flags.

Six remaining ships appear to have strong ties to North Korea

Six remaining ships appear to have strong ties to North Korea or a network of paper companies based out of Hong Kong. The total falls short of Mongolia’s claim of 14, but some changes may take longer to propagate through Marine Traffic’s databases.

A further seven ships continue to be listed as having Mongolian flags by the NK News ship tracker, indicating these vessels could be in the process of changing flags, or the changes have yet to update. But without the release of a definitive list, it’s difficult to be certain if the seven vessels which are still listed as having Mongolian flags by Marine Traffic have been de-registered, or if the original total of 14 ships is accurate.

ZERO-SUM GAME

According to the data, two of the ships which used to sail under Mongolian flags are included in Resolution 2270’s list of 27 blacklisted vessels. Half of the Mongolian-flagged ships broadcast positions in North Korean waters in the last two months, while others have ties to networks of paper companies in Hong Kong.

All of the vessels except one have broadcast their positions within the last three months, indicating they remain relatively active. The continuing ship activity raises a problem for the vessels’ new flag states.

The Marine Traffic data, port inspection records, and the Equasis Maritime database indicate only one of the ships is now sailing with a North Korean flag.

The continuing ship activity raises a problem for the vessels’ new flag states

But reregistering a ship that another country has struck off could also be a breach of Resolution 2270 if the UN has not previously cleared the new registration.

“(Resolution 2270 calls on) Member States not to register any such vessel that is de-registered by another Member State pursuant to this paragraph,” it reads.

So while Mongolia may no longer be in breach of the most recent resolution, the transfer to new shipping registries indicates that Tanzania, Togo, Cambodia, Sierra Leone and Kiribati could be in violation of sanctions if they accepted the registrations after March this year.

Tanzania seems to be most in danger of having broken the new regulations. According to the data provided by Marine Traffic, five ships changed flags from Mongolia to the African nation in four months. The process began on March 2, the same day the UN passed Resolution 2270.

The UN’s implementation page indicates Tanzania has never filed any reports implementing UN sanctions on North Korea.

SINKING SHIP

The most beleaguered vessel struck off the Mongolian registry was the Dawnlight. The ship is relatively infamous and was even the subject of a Washington Post feature in February this year.

The ship is blacklisted by the UN, the U.S. and was previously owned by a Singaporean company which helped North Korea smuggle weapons. According to the Equasis Maritime Database, it ended up in the hands of Sinotug Shipping, a company in the Marshall Islands with a limited footprint.

The Dawnlight’s troubles did not end there

But the Dawnlight’s troubles did not end there. Despite changing its name and flag, the Marshall Islands authorities took action against Sinotug earlier this year.

“Ownership of a sanctioned vessel by a Republic of the Marshall Islands (RMI) business entity is against the policy of the RMI Registrar of Non-Resident Domestic Corporations and the intended use of an RMI registered business entity.  Accordingly, Sinotug Shipping Limited was annulled on 27 April 2016,” Laura Sherman from the country’s shipping registry told NK News.

The continued measures against the Dawnlight – now called First Gleam – have likely reduced its options, but it is not idle. Despite the sanctions and designations, the ship broadcast its position earlier this week, skirting Japanese waters.

The vessel, along with others included in the UN’s blacklist is likely limited to running cargoes between DPRK ports on either side of the Korean Peninsula.