EU Today has released a research white paper on Russia’s “shadow fleet” and the wider logistics network that has evolved around maritime sanctions and the G7/EU oil price cap.
The study sets out how the trade has adapted since 2022, the risks now concentrated in European approaches, and a series of practical measures for EU institutions, Member States and industry to harden verification and reduce exposure.
The paper concludes that sanctions have changed the way the market clears, rather than extinguishing, illicit trade. When the price cap does not bind at prevailing prices and documentation is in order, flows move through a compliant channel using mainstream transport, insurance and classification. When the cap binds or enforcement cadence tightens, volumes switch into a shadow channel that substitutes non-Western services and deploys practices that reduce regulatory visibility, such as multi-stage ship-to-ship transfers, identity churn and manipulated vessel tracking. The result is a dual-track equilibrium in which trade switches in response to enforcement and economics.
Scope and method
The study covers the 2014–2025 period, anchored in the EU’s legal framework—Council Decision 2014/512/CFSP and Council Regulation (EU) No 833/2014—and the price-cap guidance developed with Coalition partners. It draws on official instruments, market data, Port State Control records and open-source maritime evidence, with replication notes and indicator thresholds set out in the annexes. The evidential rule is clear: primary law and official guidance prevail on scope and obligations; observed behaviours are graded by confidence, and allegations are marked as such unless supported by multi-source corroboration.
What the paper means by “shadow fleet”
For the purposes of the analysis, “shadow fleet” denotes a cohort of predominantly older crude and product tankers that exhibit two or more high-risk attributes: opaque or frequently changing ownership and control; renamings and re-flagging, sometimes with brief stateless intervals; insurance opacity, often outside International Group Protection and Indemnity (P&I) structures; the Automatic Identification System (AIS) manipulation, including extended dark segments or spoofing; and systematic use of multi-stage ship-to-ship transfers and blending that complicate verification of price and provenance. A related category—“grey shipping”—covers trades that are formally compliant under the price-cap regime but carry elevated operational risk indicators and therefore warrant enhanced diligence.
Key findings
A durable dual-track trade. The paper’s central judgement is that measures since 2022 have re-routed and reshaped Russia’s seaborne exports rather than ending them. Compliance rises when caps are non-binding and documentation is available; substitution into opaque logistics rises when caps bind or verification tightens. The switching is sensitive to enforcement pulses, outright price levels and the capacity of substitute services.
Costs are higher across the system. Longer voyages to Asian refiners, elevated tonne-miles, risk premia on Russia-linked lanes, ship-to-ship fees, insurance substitution and inspection delays depress netbacks relative to a no-sanctions counterfactual. In some phases, discounts narrowed as non-Western services scaled, but logistics costs and documentary burdens kept margins under pressure. Export revenues remain material, but they are earned at lower efficiency and with greater operational exposure.
Environmental and safety risks are concentrated in European corridors. The highest-risk combinations—older hulls, unclear insurance and identity churn—coincide with narrow waterways and busy approaches. The paper highlights casualty scenarios involving hose or valve failures during offshore transfers, engineering failures in the Turkish Straits and groundings near anchorages used for transfers. Where cover is opaque, claims recovery can be slow, raising fiscal exposure for coastal states. Investigative work using SAR and AIS has documented slick events involving high-risk cohorts, and PSC records show elevated deficiency counts in older tankers with identity changes and irregular documents.
Security externalities. The same behaviours that frustrate sanctions monitoring also degrade maritime domain awareness: discontinuous tracking, loitering in infrastructure corridors and rapid re-registration increase the burden of distinguishing routine from abnormal behaviour. Allegations linking commercial hulls to uncrewed aerial systems are treated cautiously; the report focuses on actions clearly available under international and EU law. The legal position remains stable: exclusive flag-state jurisdiction on the high seas, limited rights of visit, and robust port-state powers once jurisdiction is engaged.
Not a single organisation, but an assemblage. The “fleet” comprises ageing Aframax, Suezmax and product tankers operated via single-purpose companies, permissive registries and insurers outside the International Group. Trades are choreographed through ship-to-ship belts in the eastern Mediterranean and, episodically, in Atlantic approaches and off West Africa. Buyers are concentrated in Asia, with intermediary roles in Türkiye and Gulf jurisdictions. Weaknesses in the documentary chain arise where service providers accept upstream representations without sufficient validation, or where multi-stage transfers are not matched by independent surveys and custody records.
Enforcement outputs have bite—and trigger adaptation. Since 2024, guidance updates, listings with continuity identifiers, targeted inspections, port-entry denials and a small number of confiscations have produced behavioural responses consistent with theory: accelerated renamings and flag switches after adverse publicity or detention, route adjustments to avoid active inspection zones, and increased use of opaque insurers. Because these moves are costly, predictable and sustained enforcement raises the “shadow premium” even if volumes persist.
Typologies of evasion and operational signatures
The paper sets out five modalities: AIS disabling or spoofing; multi-stage ship-to-ship transfers and blending; identity management via renamings, re-flagging and brief stateless intervals; insurance substitution and document anomalies; and price-cap attestations and segmented payments that minimise visibility. Each has a technical footprint and corresponding enforcement touchpoints.
For AIS, the test is convergence: gap location and duration, kinematic plausibility, repeated pairings near transfer belts, and documentary reconciliation of tracks with port declarations and bills of lading. For ship-to-ship (STS), the distinction is between supervised single-stage transfers with full survey documentation and multi-stage chains designed to thin the audit trail. For identity churn, the anchor is the IMO number coupled with dated histories of names, flags, Maritime Mobile Service Identity (MMSI), class and insurance.
For insurance, verification through club portals or API, survey currency and class status at the time of voyage are decisive. For attestations, escalation to price-knowing Tier-1 documents is expected where red flags are present.
Trade reorientation and fiscal significance
Following the embargo on seaborne imports and the services prohibitions, exports were re-oriented toward buyers in Asia, with route elongation and higher utilisation of Aframax and Suezmax classes suited to Baltic and Black Sea liftings. Revenue effects have been variable, driven by three moving parts: benchmarks; discounts to Urals/ESPO; and whether the cap is binding at the point of sale. In the paper’s framing, the key fiscal variable is netbacks after discounts and logistics costs, not volumes per se. Shadow-fleet logistics preserve carriage but at higher cost, smoothing receipts while reducing efficiency.
Risk concentrations and coastal-state exposure
The report identifies specific risk concentrations in European approaches: the Danish Straits and the English Channel for Baltic flows; the Turkish Straits and Aegean for Black Sea flows; STS belts in the eastern Mediterranean and south of mainland Greece; and episodic activity off West Africa and in Atlantic approaches.
The consequence profile includes increased expected loss from offshore spills, groundings and engineering failures in constrained waterways. Liability and compensation remain governed by CLC/Fund instruments, but recovery probabilities and timelines depend on the real capacity behind presented certificates, which may be opaque outside International Group structures.
What has worked—and what has not
On the enforcement side, the mix of guidance, listings and targeted PSC activity has produced observable changes in behaviour and raised costs for high-risk operators. The paper’s interim judgement is that predictable, rules-based verification at access points is more effective than episodic interdiction late in the voyage cycle. On the policy side, gaps persist where counterparties rely on attestations without substance, where registries do not publish continuity logs, and where STS activity is unsupervised and poorly documented.
Practical recommendations
The white paper proposes a set of upstream, legally available measures. They are framed to be tractable for authorities and proportionate for the market.
Verification uplift on defined red-flag combinations. For voyages exhibiting multi-stage STS, identity churn and tracking anomalies, service providers should be required to hold audit-ready, price-knowing documentation rather than Tier-2 attestations alone. Where counterparties cannot produce upstream materials, services should be declined or conditioned.
Model port-access gates for high-risk cohorts. Entry and anchoring permissions should be conditioned on direct, API-based confirmation of insurance and class, recent survey evidence and complete transfer documentation. Conditions of class, suspended surveys or unverifiable insurance would justify refusal or enhanced inspection, subject to safety and humanitarian exceptions.
Insurance recognition standard for sensitive waters. A transparent recognition standard would set objective solvency and claims-handling thresholds for P&I capacity used in constrained waterways and critical approaches. This is aimed at improving recovery in casualty scenarios without prescribing specific providers.
Supervised transfer zones. Defined STS areas with surveyor presence, weather minima and central logging would reduce offshore spill risk and improve audit trails. Authorities could sequence implementation, starting with known belts in the eastern Mediterranean, and publish event data in machine-readable form.
Listings that include continuity identifiers. Vessel listings should systematically include IMO numbers, prior names, flags and MMSI histories, supported by machine-readable registry event logs. This reduces the payoff from rapid re-flagging and alias cycling.
Digital verification as default. Clubs, class societies and registries should normalise API confirmation of status and survey currency. Ports should adopt pre-arrival digital gates that reconcile insurance, class and registry data against the intended voyage. Randomised post-call audits would sustain deterrence.
Evidence-preservation protocols. Where detentions occur, authorities should secure VDR and ECDIS data, communications logs and crew statements to support consequential outcomes and structured learning.
Indicators to watch
The paper advises measuring effectiveness through a transparent suite of indicators rather than headline announcements. On prices: discounts to benchmarks and reconstructed netbacks, annotated with cap resets and guidance updates to distinguish binding from non-binding phases.
On logistics: tonne-miles and freight premia; the share of voyages on non-verifiable insurance; and transfer incidence inside and outside supervised zones. On governance: detention yields for targeted cohorts; registry event latency; and claims settlement timelines. A composite “shadow-pressure index” is proposed, combining non-IG insurance share, unsupervised transfer incidence and identity-churn intensity to give an early-warning signal of adaptation.
Case material
The document includes anonymised vignettes and documented cases covering: slick events corroborated by SAR/AIS in European waters; identity churn with a brief stateless interval on Baltic–North Europe routes; detentions leading to confiscation under EU jurisdiction; Turkish Straits chokepoint risks; multi-stage STS chains in the eastern Mediterranean; alleged UAS-related activity linked to a commercial hull (treated as alleged); and insurance certificate anomalies leading to denial of port entry.
Each case is graded by evidence quality, with sources and confidence levels, and used to inform targeting thresholds and port-access conditions.
Outlook
The balance between compliant and shadow channels will depend on outright prices, enforcement cadence and the capacity of substitute services. If prices remain high and verification static, the incentive to use opaque logistics persists. If Coalition partners align red-flag triggers and Member States harden documentation gates at access points, the compliant channel should reclaim share during non-binding phases while residual shadow logistics become more expensive and less attractive.
Success is defined not as the disappearance of shadow practices—a low-probability outcome while global demand remains robust—but as a durable increase in the shadow premium, migration towards supervised and verifiable operations, and reduced coastal-state exposure evidenced by faster claims recovery and fewer high-severity incidents in constrained waterways.
Why this matters for Europe
For European authorities, the operational risks identified in the paper—offshore spills, engineering failures in chokepoints, and the governance cost of reduced maritime domain awareness—translate into direct exposure for coastal states. The measures proposed are legally available under existing instruments and focus on predictable, early frictions rather than ad hoc interdictions.
For industry, the recommendations point to clearer expectations: audit-ready documentation on red flags; verifiable insurance and class; supervised transfers; and digital verification as the norm. For legislators, the emphasis is on data: machine-readable continuity identifiers, registry event logs and exportable PSC outcomes.
Publication details
Russia’s Shadow Fleet: Sanctions Evasion on the High Seas — A White Paper on Maritime Sanctions, Shadow Logistics and European Risk Exposure is issued by the EU Today Research Desk (October 2025). It is based on open-source intelligence, EU legal instruments, maritime datasets and Port State Control records, and is intended for a general readership, policy practitioners, maritime authorities, industry stakeholders and legislative advisers.
