The concept of “shadow fleet” is not just a method of evading sanctions, but it is a systemic challenge to international maritime law, security, and the environment, which demonstrates the capacity of states and relevant actors to create parallel structures to protect their revenues under strict restrictions. Combat and/or prevention of this phenomenon requires a comprehensive approach, from sanctions and legal enforcement to international cooperation, strengthening inspections, and innovative monitoring technologies.
If not effectively addressed, the shadow fleet could weaken the economic impact of sanctions, increase environmental risks, and become a new geopolitical battleground. The current structure of the global merchant fleet is characterized by a practice where growing number of ships are being registered under “Flags of Convenience” (F.O.C.), thus allowing owners to circumvent stricter regulations, reduce their tax liabilities, and minimize inspection by international organizations. This leads to a non-transparent property system, making it difficult to identify true beneficiaries and, consequently, to properly inspect ships’ technical condition and compliance with international safety standards.
The insurance policies of such vessels also raise additional concerns. Many are minimally insured by lesser-known companies or lack full insurance coverage in Western or other major international pools. This situation gets the risks increased for states and companies who are involved in maritime trade, as liability for damage may be unresolved or shifted to the buyer in the event of an accident. The age of the fleet is also a significant risk factor. A significant portion of these tankers are older vessels nearing the end of their technical lifespan. Operating older vessels increases the likelihood of accidents, oil spills, and other incidents that could lead to environmental disasters and disrupt trade flows. This situation gets even worsened by the questionable reporting practices common among operators of these vessels. Regular flag changes, tricky proprietorship chains, and illegal or semi-legal cargo transfers on the high seas make it difficult to trace the routes and origins of cargos such as oil, etc. These practices significantly undermine the transparency of global maritime trade and complicate compliance with international sanctions and environmental regulations. All these factors combined create a perpetual “gray area” in global maritime shipping, where economic interests outbalance safety and environmental responsibility. Interest in this phenomenon has increased since the outbreak of the Russo-Ukrainian War in 2022, when the shadow fleet emerged as a key tool for circumventing sanctions.
After the G7 countries and Australia imposed price caps on Russian oil in December 2022, Russia rapidly began building a shadow fleet of tankers that could be used to work around Western sanctions and ensure oil was sold at market prices. While Western sanctions cover a wide range of oil services beyond simple transportation, the existence of a shadow fleet and the emergence of the Russian insurance sector have enabled Russian producers to increasingly circumvent Western restrictions.[i]
Russia continues to expand its shadow fleet, used to export energy resources while evading sanctions. It is estimated that they account for one in six tankers worldwide, which makes it approximately 17% of the global market. These are decommissioned vessels that have reached the end of their service life and fly the flags of nonbelligerent countries.[ii] It’s worth noting that the threat isn’t limited to environmental risks or illicit oil trade. These tankers have also become hybrid combat vehicles, used by the Kremlin as attack and espionage platforms in European waters.[iii]
If a significant portion of energy exports are carried out through the shadow fleet, the effectiveness of sanctions will be reduced. Trends suggest that Russia’s stay-behind fleet will continue to play a key role in the country’s export strategy, especially if sanctions pressure persists. Unless the West strengthens sanctions, coordination and addresses weaknesses in insurance and port access regulations, further increases in the number of such vessels are expected.
Countermeasures include tightening insurance regulations, for example, restricting access to insurance services for ships in the shadow fleet. Another important step is international cooperation, particularly in which the states whose ships are involved in such operations work together, to detect and combat sanctions evasion schemes.
In this context, the European Union continues to work on its 20th package of sanctions against Russia, which aims, among other issues, to maximize the efficiency of the measures targeting tankers carrying Russian oil. Following the EU Foreign Affairs Council meeting on November 20, EU Commission Spokesperson Anitta Hipper has stated that “the focus of the discussion is on the issue of the shadow fleet and how we can act more effectively to make our sanctions packages more targeted to reduce Russia’s revenues, focusing particularly on shadow fleets.”[iv] Speaking at a press conference in Brussels following the European Council meeting, EU High Representative for Foreign Affairs and Security Policy Kaja Kallas had previously emphasized that “disrupting the activities of Russia’s stay-behind fleet remains their priority” and that they have held intensive discussions on what further measures can be taken. Kallas also underlined that “the EU has already imposed sanctions on over 550 ships and has conducted extensive diplomatic talks with the flag states where these ships are registered” and that their current goal is to reach preliminary authorization agreements with them. This is, according to Kallas, a legally binding way for one country to inspect another’s ship, while also continuing to working for expand of the sanctions against the shadow fleet, including both the ships themselves and their intermediaries.[v]Unfortunately, the EU does not have complete information on all ships in the shadow fleet for various reasons. For example, ships frequently change their names, ownership structures, and countries of registration, and also fly false flags or flags of opportunistic countries.[vi] The appointment of a coordinator in the EU’s foreign policy department, to combat the shadow fleet that transports Russian oil to evade sanctions, could be seen as a significant step for the union.[vii]
Therefore, the EU aims to move from far-reaching sanctions targeting critical elements of Russian energy export chains to more targeted measures. Strengthening controls over the shadow fleet and involving intermediaries in the process, creates a multi-layered barrier for the evasion of sanctions. This could significantly reduce Russia’s revenue from oil exports. Therefore, the EU continues its active efforts to increase sanctions pressure on Russia by focusing on limiting the activities of the shadow fleet and monitoring the transportation of Russian oil. The EU aims to make sanctions more targeted and effective by using both diplomatic negotiations with flag states and legally binding ship inspection mechanisms. These measures aim to reduce Russia’s revenues and underscore the EU’s commitment to enforcing the sanctions regime.
In this context, these decisions taken by the West could be seen as a precondition or a solid foundation for an anticipated conflict with China in the near future. Indeed, China possesses significant experience in maritime trade, as well as ambitious land transportation and logistics projects. Due to geographical and historical circumstances, maritime transportation routes have been of primary importance to China in maintaining trade relations with Western countries. It is therefore understandable why China is so heavily involved in the construction of its transportation infrastructure. Here it seems important to draw attention to the Belt and Road Initiative, which brings together the two projects. It appears that, for some time now, Beijing has been learning from Russia’s foreign policy actions and mistakes.
The Cold War experience has contributed to the development of a virtual “immunity” against any political turmoil that Russia faces. The recent US “peace plan,” approved by Russian President Vladimir Putin, is fueled by an almost deprecating attitude toward Moscow’s aggressive and invasive actions, or by concessions. It seems that the Washington administration is not interested in the essence of what is happening in Europe or does not want to continue preventive measures against Russian aggression due to its own trade and economic concerns. Unless a well thought out and consistent policy emerges from Western states, even the smallest concessions or insignificant decisions strengthen Moscow’s strategic position.
[i] Robin Brooks and Ben Harris, “The race to sanction Russia’s growing shadow fleet”, Brookings Institution,https://www.brookings.edu/articles/the-race-to-sanction-russias-growing-shadow-fleet/?utm_source=chatgpt.com, (Access Date: 29.11.2025).
[ii] “EU prepares new strike on Russia’s shadow fleet”, RBC-Ukraine, https://newsukraine.rbc.ua/news/eu-prepares-new-strike-on-russia-s-shadow-1763645326.html, (Access Date: 29.11.2025).
[iii] ibid.
[iv] “Preparation of 20th package of EU sanctions against Russia especially targets tankers with Russian oil – European Commission rep”, Interfax, https://interfax.com/newsroom/top-stories/114954/, (Access Date: 29.11.2025).
[v] ibid.
[vi] Ксения Польская, “В ЕС назначили координатора по борьбе с “теневым флотом”, Deutsche Welle, https://www.dw.com/ru/v-es-naznacili-koordinatora-po-borbe-s-tenevym-flotom/a-74795532, (Access Date: 29.11.2025).
[vii] ibid.
