Shadow Fleet

Definition and terminological overlap

The IMO Assembly adopted Resolution A.1192(33) on 6 December 2023, giving its first precise, conditional definition of dark or shadow fleet ships and listing examples: unsafe operations, intentional avoidance of flag and port State control inspections, failure to maintain adequate liability insurance, avoidance of commercial screenings, opaque corporate governance, and intentional measures to avoid detection such as switching off AIS or LRIT transmissions or concealing a ship's identity. The European Parliamentary Research Service (EPRS) notes that this narrow, purely illegal-practice definition may be insufficient to grasp the wide spectrum of practices Russia adopts. The dark, grey and shadow fleet labels have no consistent definition and are used interchangeably by journalists and politicians, making the scale of the phenomenon difficult to assess. Analysts increasingly use broader criteria, such as the KSE Institute's two conditions of lacking Western insurance and relying on providers outside the International Group of P&I Clubs, and belonging to non-EU/G7 companies.

Origins and expansion

After the 2022 invasion of Ukraine, the EU embargoed seaborne Russian crude effective 5 December 2022 and most petroleum products effective 5 February 2023, covering about 90 percent of EU oil imports from Russia. In parallel the EU, G7 and participating states imposed a price cap, transposed into EU law in October 2022, initially USD 60 per barrel for crude and unchanged since, prohibiting companies under participating jurisdictions from providing shipping, brokering, technical assistance or insurance unless the trade was verifiably below the cap. Because EU and G7 companies dominate maritime insurance and shipping, Russia rebuilt supply with vessels whose ownership and insurance sit outside G7 and EU jurisdictions. Shadow or dark fleet use is not new: Iran, the DPRK and Venezuela resorted to it regularly before, but Russia took it to another level in numbers and in the sophistication of its mechanisms. Reports put the Russian shadow fleet at over 600 ships by the end of 2022, 400 of them crude oil tankers, and at 1,100 to 1,400 ships by December 2023, of which 118 had been sanctioned by the US, EU or UK. Scale figures are source-dependent and are better attributed than collapsed into a single number.

Operational techniques

Documented techniques include complex company ownership and management structures, flags of convenience and frequent renaming, concealing cargo origin through ship-to-ship transshipment, disabling transponders, transmitting false data, AIS blackouts and spoofing, and in one case changing the ship's IMO number. AIS blackouts usually occur approaching high-risk areas such as transshipment zones, and vessels may re-enable AIS near port to appear compliant. Vessel identity laundering is a more sophisticated technique that exploits flaws in the IMO numbering system. The tanker Boracay, boarded by French naval forces off Saint-Nazaire on 30 September 2025, had previously sailed as Pushpa, Odysseus, Varuna and Kiwala and had flown the flags of seven different countries; French authorities later determined it was the Kiwala seized by the Estonian Navy in April 2025.

Commercial effect and safety and environmental risk

The fleet lets Russia sell oil above the G7 and EU price ceiling. KSE estimates that in the first nine months of 2024 alone the shadow fleet let Russia realise USD 10 per barrel more, generating USD 8 billion in extra earnings, with India, China and Turkey the top crude destinations. Insurance is the hinge of the practice: P&I cover is mandatory for internationally trading vessels and covers collisions, property damage, pollution, wreck removal and civil liability, and the International Group of P&I Clubs covers over 90 percent of world ocean-going tonnage. Sanctions stop G7 and EU insurers from covering Russian-origin crude and products sold above the cap, so much of the fleet relies on Russian or offshore insurers such as Ingosstrakh, and investigations document falsified or expired insurance certificates. Safety risk is already material: over 72 percent of shadow tankers are more than 15 years old, heightening the risk of malfunctions, collisions and spills, and more than 50 incidents have involved Russia's shadow fleet. Two 50-year-old tankers spilled 5,000 tonnes of crude in the Kerch Strait in December 2024, which Russian Academy of Sciences president Viktor Danilov-Danilyan called the worst environmental disaster of that kind in Russia this century. Because these vessels fly flags of convenience, operator liability is limited and accountability is complicated, so response costs often fall on other vessels' insurers or on local governments. EPRS warns that without adequate P&I insurance the immediate funds to contain spills early are lacking, and that expansion of the fleet with ageing, minimally maintained vessels is likely to increase accidents and strain coastal-state response resources.

Countermeasures and enforcement

On 16 December 2024 twelve countries (Britain, Germany, Poland, the Netherlands, Denmark, Finland, Iceland, Norway and Sweden, and Estonia, Latvia and Lithuania) agreed to cooperate to disrupt and deter Russia's shadow fleet and prevent sanctions breaches. The US Treasury sanctioned about 180 vessels plus traders, oil companies and Russian oil executives on 10 January 2025; Australia sanctioned 60 vessels in June 2025; and the UK sanctioned 135 oil tankers in July 2025. Enforcement incidents include Finland boarding the Cook Islands-registered Eagle S on 26 December 2024 over the severing of two submarine communications cables; Germany detaining the Panama-flagged Eventin on 21 March 2025 with about 100,000 tons of sanctioned Russian crude and confiscating the cargo, a decision contested after a Munich court ruled in December 2025 that ships in distress entering German waters were not to be seized; Estonia seizing the flagless Kiwala on 11 April 2025 and releasing it on 28 April; and France seizing the sanctions-listed Boracay on 30 September 2025. The Russian Navy began escorting shadow fleet tankers in convoys for the first time on 16 June 2025, with the Selva and Sierra guarded by a corvette, and the convoy passed the English Channel on 22 June. In late November 2025 Ukraine's SBU conducted drone strikes on the shadow fleet tankers Virat and Kairos off the Turkish Black Sea coast and claimed responsibility, and in December 2025 it carried out its first long-range Mediterranean strike on a tanker that had recently delivered oil to India.

Distinctions and boundaries

A 2013 IMO report already recorded that high-seas ship-to-ship transfers were high-risk activities undermining the international regime on maritime safety, environmental protection and liability. Three-tier industry schemes distinguish a cleared fleet, a grey fleet whose legality is hard to assess and a dark (shadow) fleet using deceptive and illegal practices such as identity and location tampering or disabling AIS, placing both grey and dark in a risky category. S&P Global estimates that nearly one in five of the world's seaborne tankers now belongs to a shadow fleet of ageing, opaquely flagged ships carrying oil from sanctioned states, of which 50 percent carry Russian crude and products only, 20 percent Iranian only, 10 percent Venezuelan only and 20 percent cargo from multiple sanctioned states. Counter-evidence qualifies the maximalist framing: as experts from Carnegie Politika emphasise, the concept of a distinct shadow fleet dedicated solely to evading sanctions may be overstated, since shadow fleet ships often work only part-time for Russian clients. On the contested security dimension, senior Washington Post sources in US and EU intelligence concluded in January 2025 that Russia was not responsible for Baltic cable damage and that the incidents resulted from inexperienced crews. Legally, ships enjoy the right of innocent passage through territorial waters under UNCLOS, and the Copenhagen Convention of 1857 guarantees merchant vessels the right of peaceful passage through the Danish Straits, which limits enforcement against ageing vessels carrying Russian crude.

Other shadow fleets and limits

Shadow fleets are a general sanctions-evasion phenomenon rather than a Russia-only one, having been used by Iran, the DPRK and Venezuela. Iran uses a global network of vessels registered in convenience jurisdictions such as Panama, Liberia, Palau, Gabon and Tanzania that switch off AIS on the high seas and transfer oil ship-to-ship in neutral waters to hide Iranian origin, with China the main buyer and international front companies as the key financial node. China uses opaque shipping companies, tankers and civilian vessels to circumvent sanctions, including its own shadow LNG carrier fleet that disables transponders, uses satellite spoofing and conducts risky ship-to-ship transfers near Singapore or Malaysia. The DPRK's shadow fleet responds to multilateral sanctions imposed after nuclear and ballistic missile tests since 2016, maintaining imports and financing the state through the export of iron ore, coal and textiles as well as weapons sales.

Disputed points

Russian investment in the shadow fleet is estimated at about USD 10 billion, with a separate Russian-language figure referring to spending since February 2024; UK Foreign Secretary David Lammy is cited stating Russia spent more than USD 8 billion to create the fleet. Russia built it by shifting roughly 90 Sovcomflot-owned tankers to management companies in the UAE and elsewhere before 5 December 2022, and by buying vessels over 15 years old that had previously held International Group P&I insurance, about 100 of them. Over 200 vessels of 20 years or more that would likely have been retired if not repurposed were acquired. EPRS notes the exact number of shadow vessels and tankers remains unknown, listing S&P Global at approximately 591 shadow tankers in the Russian oil trade (271 as dark fleet) and KSE's 2024 report at around 435 vessels. KSE estimates shadow tankers carried 4.1 million barrels a day in June 2024, 70 percent of Russia's total seaborne exports. Analysis of the fleet touches governance, insurance, freedom of navigation, safety, the environment and geopolitics, and the practice is a representative case of shadow trade that exposes both the reach and the limits of the sanctions regime.