PolicyBrief
S. 1103
119th CongressMar 25th 2025
Vessel Tracking for Sanctions Enforcement Act of 2025
IN COMMITTEE

This Act establishes a four-year pilot program using big data analytics to detect vessels evading U.S. sanctions by analyzing suspicious Automatic Identification System (AIS) activity.

Margaret "Maggie" Hassan
D

Margaret "Maggie" Hassan

Senator

NH

LEGISLATION

Feds Launch Four-Year Data Pilot Program to Track Ships That 'Go Dark' to Evade Sanctions

The Vessel Tracking for Sanctions Enforcement Act of 2025 isn't about changing trade laws; it’s about changing how the U.S. government catches people breaking them. Specifically, this bill sets up a temporary, four-year pilot program run by the Department of Homeland Security (DHS) to test whether advanced data analysis—what the bill calls "big data analytics"—can effectively spot ships trying to sneak goods past U.S. sanctions and export controls.

The Digital Trail of Evasion

Think of it like this: every major ship is required to run an Automatic Identification System (AIS), which is basically a GPS tracker that broadcasts its location to prevent collisions. When a ship suspiciously turns its AIS off—or "goes dark"—it’s often a sign that it’s doing something it shouldn’t, like delivering oil to a sanctioned country. This pilot program, based out of the Customs and Border Protection (CBP) National Targeting Center, is designed to crunch massive amounts of data to flag these suspicious dark voyages. The system will look at factors like the ship’s cargo, its owners, its destination, and how often it has previously had "AIS problems." If a ship has a history of going dark near sanctioned ports, this new system will flag it as high-risk.

Intelligence Sharing and Real-World Impact

This isn't just an exercise in data crunching; the intelligence generated is meant to be actionable. The bill mandates that the intelligence be shared with federal law enforcement, including the Coast Guard and Immigration and Customs Enforcement (ICE), so they can interdict the vessels. They can even share this information with partner countries, effectively making it harder for illicit shippers to hide anywhere. For regular businesses—the legitimate shipping companies, importers, and exporters—this could mean a slightly smoother process if their records are clean, as enforcement resources will be more accurately focused on actual bad actors. However, it also means that the margin for error is shrinking for anyone trying to cheat the system.

A Test Run with a Clock

This whole program has a built-in expiration date: four years after the law is enacted, the pilot automatically ends. Before that deadline, DHS must report back to Congress on how useful the big data system actually was. The report has to detail specific success stories, like what penalties were issued when a high-risk ship was caught, or what happened when a high-risk ship got away (did it end up in a sanctioned country?). Crucially, the bill explicitly states that this program must run on existing funds and is not authorized to collect any new types of data that the government wasn't already legally allowed to collect. This means the system is testing better analysis of existing data, not a massive expansion of surveillance. If it works, expect to see this kind of data-driven enforcement become the new normal for global trade security.