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Two Systems, One Jurisdiction: Why Maritime Finance Still Runs on Paper

Aug 17
7 min read
Blue Shipfinex graphic with hourglass shape and text: TWO SYSTEMS on left, ONE JURISDICTION on right.

Ravi Shankar FICS, Chief Commercial Officer, Shipfinex. Chairman, Institute of Chartered Shipbrokers, Middle East.


How a ship actually changes hands

Start with the transaction, because everything else follows from it.

A vessel is sold. Brokers negotiate the terms. A Memorandum of Agreement is signed, most often on the Norwegian Saleform 2012, sometimes on Nipponsale or the Singapore Ship Sale Form. A deposit, conventionally ten per cent, goes into a joint account held by neither party alone. The buyer inspects the vessel and her classification records. Delivery takes place at an agreed port or anchorage, and a Protocol of Delivery and Acceptance is signed by both sides and timed to the minute, because the minute matters for bunkers, for hire, and for risk.


Blue infographic titled The Sale and Purchase Paper Trail showing 9-step ship sale process with documents, stamps, arrows, handshake icon

Then the paper moves. A Bill of Sale, notarised and legalised. A Deletion Certificate from the outgoing registry, confirming the vessel has been struck off and any mortgage discharged. Registration with the incoming flag, and a new Certificate of Registry issued. The balance moves by telegraphic transfer through correspondent banks on delivery.


Now ask where the record of that transaction lives. It lives at two flag registries. It lives with a classification society. With the seller's bank and the buyer's bank, frequently in different countries. With two firms of lawyers, two broking houses, and the two principals. Every one of them holds a version. Not one of them holds the version.


Blue infographic titled Where the Record Lives, with a circular chain of registry, bank, lawyer, and broker labels and a note.

Most vessels are delivered with a mortgage registered against them at the flag registry, and the mortgage is the reason a closing is choreography rather than paperwork. The seller's bank will not release its security until it has the money. The buyer will not pay until it is certain of clean title. The industry's answer is a closing conducted in a defined sequence, usually with lawyers holding pre-signed documents in escrow: funds are confirmed received by the seller's bank, the bank releases the executed discharge of mortgage, the discharge is filed at the registry, and only then can the vessel be deleted free of encumbrances. Every step depends on the one before it, several depend on a registry counter being open in another time zone, and the whole structure is held together by lawyers' undertakings rather than by any shared system.


In practice, closings slip for reasons that would sound trivial anywhere else. A wire misses a correspondent bank's cut-off and delivery moves to the next day, with the vessel waiting at anchorage and both sides watching the cancelling date. A notarisation or apostille is defective and a registry rejects the document. A sanctions screen holds a payment for hours with nobody able to say why or for how long. The bank's internal release approval sits with someone in a different time zone. None of this is exotic. It is the ordinary friction of moving evidence between institutions that do not share records, and every sale and purchase broker has watched a delivery held up by a single piece of paper.


And the tail is longer than the closing. Delivery is not the end of the record's journey. The formal Deletion Certificate from the outgoing registry frequently follows weeks after delivery, with the seller giving a contractual undertaking to produce it. The buyer's flag typically issues a provisional Certificate of Registry, and the vessel trades on provisional papers while the permanent registration catches up. Reconciling the complete documentary record across two registries, two banks and two sets of lawyers is measured in weeks after the money has already moved. The asset changes hands in a day. The record takes a month to agree that it did.


I want to be fair to the system I have just described. It works. It has moved more cargo and financed more tonnage than any other arrangement in commercial history, with a fraud rate most asset classes would envy. It is simply built for a small number of counterparties who know each other, and it does not extend gracefully to a larger number who do not.


The scale of what is being recorded this way


Infographic titled THE SCALE CARD with globe, ship, and bank icons showing trade, fleet value, and ship finance stats.

Over 80% of international trade in goods is carried by sea by volume. Source: UNCTAD, Review of Maritime Transport 2025. It means the arrangement above is not a niche problem in a corner of finance.


At the end of 2025, the global fleet and orderbook was valued at approximately $2.17 trillion. That figure is Clarksons', cited in Petrofin Global Bank Research's report of July 2026. The same report puts total global ship finance at around $680 billion once leasing, export credit and alternative providers are counted alongside bank lending.


Two trillion dollars of assets. Under seven hundred billion of financing against them. The gap is equity, and it comes from a relatively small circle of people, most of whom have known each other for thirty years.


Why it has stayed this way


This is not a technology failure, and I would ask anyone writing about our industry to stop describing it as one.


The reason there is no shared record is that shipping is a genuinely international business conducted under legal systems that do not agree with one another. A vessel is registered in one country, owned through a company in a second, financed by a bank in a third, chartered in a fourth, and detained, when things go wrong, by a port state in a fifth. A shared record requires a shared authority. The industry has never had one and does not want one.


Shipping has been offered a great deal of software over the past decade. Most of it did not survive contact with a shipowner. Some was badly built. More was built by people who had never had to explain to a charterer why a payment had not arrived, and who therefore never understood what the paper was doing. The paper is not inefficiency. The paper is evidence, and in a dispute across five jurisdictions, evidence is the only thing that matters.


Anything that replaces it has to be at least as good at being evidence. That is a much higher bar than being fast, and almost nobody who has approached this industry has cleared it.


What has been built in the UAE


Abu Dhabi Global Market operates a dedicated framework for digital assets. VARA licenses virtual asset activity in Dubai under its own regime. And ADI Chain, an EVM-compatible Layer-2 network developed by ADI Foundation, has been live since December 2025.

I would ask maritime readers to sit with the counterparty rather than the technology, because that is the order in which this industry has always assessed anything. ADI Foundation is a non-profit organisation registered in Abu Dhabi Global Market, founded by Sirius International Holding, the technology-focused subsidiary of IHC. A named entity, in a named jurisdiction, with an identifiable parent that would be embarrassed if this went wrong. In chartering and in sale and purchase, that is the first question anyone asks, and it is the question most proposals in this category cannot answer at all. This is not a start-up asking a shipowner to trust a whitepaper.


The distance between the two


Both of these systems operate in the same country. Ships are financed in Dubai. Vessels are owned through entities in the Emirates. And an hour and a half up the road, institutional digital financial infrastructure has been running under a dedicated regulatory framework since December 2025.


Neither has been connected to the other. That is a statement about infrastructure, not about price, demand, or what anything is worth.


The programme


ADI Chain and Shipfinex have entered an exclusive partnership to establish the first regulated, institutional-grade tokenized maritime asset class.


The agreement has commercial structure. Shipfinex will originate, issue and structure eligible maritime assets. ADI Chain will provide the blockchain, distribution and settlement infrastructure, and will serve as the exclusive blockchain and settlement infrastructure for the resulting digital instruments. Maritime Asset Tokens developed under the partnership will be issued through a regulated route and made available exclusively on ADI Chain.


Each eligible vessel will be held within its own legally distinct special-purpose vehicle, so that its value, liabilities, income and the rights attached to it can be assessed independently.


I want to dwell on that last sentence, because it is the part of this announcement that a shipbroker will recognise and an outsider will skim past. Ships have always been assessed one at a time. A buyer looks at her age, her yard, her class record, her survey position, her employment history and her charterer. Nobody in this market has ever valued a vessel by averaging her across a fleet. Yet fleet-level cross-collateralization is how ships are typically financed, which means a capital provider is underwriting a correlation nobody can see, and a single casualty or a single charterer default can travel across an entire book. Per-vessel isolation puts the financing structure back in line with how the asset has always actually been judged.


Blue infographic comparing fleet-level cross-collateralization with per-vessel special-purpose vehicles for ship financing.

Shipfinex brings an initial pipeline of around 35 vessels valued at approximately half a billion US dollars, and the per-vessel legal structure has already been designed. The project is now moving through the pilot and operational-readiness stage.


No Maritime Asset Tokens have yet been issued publicly. The regulated issuance route is being finalised and the initial product structure has not been confirmed. The first phase of the partnership is that work and nothing beyond it. Shipping has spent a decade declining technology that skipped that step, correctly. This one has not skipped it, and that is the part of the announcement I would ask a shipowner to take seriously.


This announcement describes a partnership and a future programme. Any product, settlement service or issuance route described remains subject to definitive documentation, applicable law and regulatory permissions. Shipfinex FZCO holds an In-Principle Approval (IPA/26/01/002) from Dubai's Virtual Assets Regulatory Authority (VARA); an In-Principle Approval is not an operating licence and does not authorise the conduct of virtual asset activities until the relevant licence is granted. No Maritime Asset Tokens have yet been issued publicly. References to anticipated capabilities are forward-looking statements.


About Shipfinex


Shipfinex is a regulated platform building the financial evolution of the maritime industry. By leveraging RWA Tokenization and Distributed Ledger Technology (DLT), Shipfinex enables ship owners to unlock liquidity and allows investors to participate in maritime assets. Shipfinex holds an In-Principle Approval from Dubai's Virtual Assets Regulatory Authority for VA Broker-Dealer services (Ref: IPA/26/01/002) and is working toward operational launch. In July 2026, Shipfinex was also granted a Limited Use Authorisation by India's International Financial Services Centres Authority (Certificate No. FNT20261108) to test the full maritime tokenisation lifecycle in the IFSCA FinTech Innovation Sandbox at GIFT City, placing the platform under supervised development in two leading international financial jurisdictions.

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