102 OFAC-sanctioned ships trace to a Hong Kong company. Two fly the Hong Kong flag.
The Hong Kong flag is Paris/Tokyo MoU white-listed and clean. Yet 102 OFAC-sanctioned vessels are linked by OFAC to a Hong Kong-registered company — 72 distinct entities, almost none HK-flagged. The exposure is in the corporate layer, not the flag. Issue 01 of the ArcNautical Hong Kong Ownership-Layer Brief.