Press & citation kit — Hong Kong Ownership-Layer Brief Issue 01

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Quotable statistics

All figures are computed from the OFAC SDN list as of 4 June 2026 (1,493 designated vessels, against the full 19,024-record SDN list).

102 vessels (6.8%) of the 1,493 OFAC-designated vessels are linked by OFAC to a co-designated entity that OFAC records as registered in Hong Kong.

72 distinct Hong Kong companies appear across those linked networks — every one resolves to a real SDN record carrying a Hong Kong company-registration number.

Only 2 of the 102 vessels actually fly the Hong Kong flag. The other 100 fly Panama (62), Barbados (7), China (6), São Tomé (5) and others — the corporate registry and the flag are decoupled.

The Hong Kong flag is white-listed on both the Paris and Tokyo MoUs (3-year detention rates 1.5% / 1.2%); just 12 of 1,493 designated vessels fly it. The sanctions exposure is in incorporation, not the flag.

By program: Iran 50, Russia 34, terror-finance / proliferation 13, Venezuela 3, DPRK 2 (each vessel counted once under its strongest state regime).

Two Hong Kong companies — Prominent Shipmanagement (13 vessels) and Sunne Co (10) — front roughly a fifth of the affected fleet on their own.

Methodology in 90 seconds

For each OFAC-designated vessel, every name in its OFAC Linked To: remark is resolved to that entity's own SDN record. The vessel is counted only when a linked record is a company whose record carries a registration field tagged (Hong Kong):

Incorporation-grade only. The keyword must be a company-registry field — Business Registration Number, Company Number, Commercial Registry Number, C.R. No., or Certificate of Incorporation — and the (Hong Kong) tag must fall in the same semicolon-delimited remark fragment, so a registration number is never misjoined to a Hong Kong address elsewhere in the record.
Companies, not people. Individual identity fields ("Passport … (Hong Kong)", "National ID … (Hong Kong)") are excluded; the matched record must be an entity.
Name-only excluded from the lead number. A softer signal — "Hong Kong" in the entity name with no registration field (3 further vessels, e.g. Hongxiang Marine Hong Kong Ltd) — is reported separately, never folded in.

The Hong Kong flag's white-list placement and detention rates come from server/arcnautical/scoring/v1/flag-performance.ts (Paris MoU 2021–2023 + Tokyo MoU 2023 performance lists).

Provenance & how to reproduce

Source: US Treasury OFAC Specially Designated Nationals (SDN) list. Public, free, well-documented.

Source URL: sanctionslistservice.ofac.treas.gov/api/PublicationPreview/exports/SDN.CSV

Data as of: 2026-06-04 (list published 2026-06-02)

Parser commit: ArcNautical production screening engine (commit 402da7a8)

Re-run: the dataset linked under Downloads lists every Hong Kong entity, its SDN id and its registration number. Anyone with the SDN.CSV file can re-run scripts/hk-tonnage-brief.ts and re-derive every figure in the Brief.

Use, attribution, contact

License: Free to cite and forward — in compliance memos, diligence notes, or coverage — with attribution to ArcNautical and a link to arcnautical.com/reports/hk-shadow-fleet-ownership-layer/01/. No embargo.

Contact: Madhav (founder) — [email protected]. Happy to share the underlying calculation or walk a specific vessel's ownership chain.

About ArcNautical: Maritime sanctions & ownership intelligence — vessel risk dossiers, ownership-chain screening, and sanctions checks for shipowners, managers, P&I underwriters, and the lawyers who run diligence for them. Independent, founder-run.