Russia’s so‑called “Shadow Fleet” operates in plain sight, turning the world’s shipping lanes into a tool of economic and ecological risk. Hundreds of these shadow tankers carry crude through European waters each day, many beyond their service life and registered under opaque holding structures. The result is a maritime environment made increasingly hazardous; between 2022 and 2024 alone, Shadow Fleet vessels were involved in dozens of incidents at sea, many of which involved oil spills.
This operation persists because, despite Western-imposed sanctions intended to restrict Russia’s access to conventional shipping, China and India remain the primary buyers of the Shadow Fleet’s cargo. Both states operate outside the G7 price cap regime and avoid scrutiny via transshipment through hubs in Singapore, Malaysia, and Indonesia. These nodes obscure origin, prevent attribution, and facilitate reintegration into global markets.
It would be easy to assume that the Shadow Fleet is only a means to evade sanctions or introduce plausible deniability for oil transactions. However, the Shadow Fleet functions as an instrument of irregular warfare by transferring environmental liability, undermining maritime law enforcement, and normalizing sanctions evasion, allowing Russia to impose strategic and economic costs on adversaries without using force. The following analysis shows that the Shadow Fleet represents a deliberate, irregular warfare approach designed to impose environmental and economic risk on adversaries without accountability or kinetic engagement. This approach creates the persistent threat of environmental and economic crises, particularly in vulnerable regions like the Baltic and North Sea, without offering clear legal recourse or accountability. Addressing this threat requires targeting the fleet’s enabling infrastructure—registries, insurers, intermediaries, and legal loopholes—rather than focusing solely on individual vessels.
Why the Shadow Fleet is a Floating Hazard
The Shadow Fleet remains afloat by exploiting the seams in countries’ legal regimes and taking advantage of falsified or non-existent insurance to avoid any liabilities and operate with impunity. Much of the Shadow Fleet’s risk stems from the advanced age of its vessels. The average Shadow Fleet vessel is 18.1 years old, compared to mainstream commercial vessels, which are nearly a decade newer, averaging 10.4 years of age. Over 75 percent are past the 15-year threshold where technical failures increase sharply. In 2022 alone, Lloyd’s List recorded 16 incidents involving Shadow Fleet tankers, including hull breaches and power loss during transit.
Adding to the physical risk, the vessels are often poorly maintained and crewed by poorly qualified mariners. Shadow Fleet tankers also pose a direct threat to seabed infrastructure, whether through malice or negligence. In December 2024, Finnish authorities confirmed that a Russian-linked tanker dragged anchor across the seabed, damaging the Estlink-2 power cable and multiple telecommunications lines. Automatic Identification System (AIS) suppression and anchor positioning patterns suggest both negligence and potential coercive activity are to blame.
Environmental risk also plays a major role. The International Tanker Owners Pollution Federation reports costs associated with each spill ranging from almost $600 to nearly $4,000 per barrel, yet most affected states cannot recover damages through courts. The Shadow Fleet’s lack of verifiable insurers or owners blocks legal redress. Responsibility for environmental harm is decoupled from exposure and affected states lack any means to enforce compliance.
Compounding these risks, Russian sanctions-evading traffic operates in what are usually narrow, seasonal routes with limited mitigation capacity. The legal framework surrounding these routes was built for flag-state responsibility and commercial transparency. Neither legal structure functions in the case of Shadow Fleet tankers, however. When vessels well past their operational prime navigate confined, high-traffic waterways, the likelihood of catastrophic failure—and the inability to contain the fallout—rises exponentially, placing surrounding nations and industries at disproportionate risk.
The Mechanics of Liability Evasion
According to Lloyd’s List and maritime compliance audits, over 70 percent of the fleet lacks verifiable Protection and Indemnity (P&I) coverage, operating without the ability to cover third-party risks such as crew injury, cargo damage, pollution, and wreck removal. In the case of the Shadow Fleet, many vessels either carry falsified certificates or list insurers that no longer exist. Without P&I coverage, cleanup and compensation costs from spills or collisions fall entirely on the affected state or commercial entity, resulting in billions of dollars in compensation costs per incident and far exceeding legal caps in existing maritime compensation frameworks.
However, increased tracking will not solve the issue. These ships are monitored in real-time by a host of navies, coast guards, maritime regulators, and commercial actors. Fragmented designation regimes across the United States (US), United Kingdom (UK), and European Union (EU) have produced jurisdictional seams and hindered enforcement. As of mid-2025, the EU has sanctioned 342 vessels, the UK 133, and the US several hundred. Overlap remains limited and enforcement mechanisms differ: the EU relies on access and service bans, the UK on hybrid compliance, and the US on financial prohibitions under the Office of Foreign Assets Control (OFAC). These differences allow Russian operators to reflag vessels, reroute cargo through non-aligned registries, and access financial and insurance systems not uniformly controlled.
The Risks in the Baltic
The Baltic and North Sea are most vulnerable to the Shadow Fleet, which hosts dense subsea infrastructure vulnerable to degraded vessels. Russia manages over 430 tankers, of which, according to KSE (Kyiv School of Economics) Institute data, 150 to 170 of these vessels transit through the Baltic Sea each month. Unlike Persian Gulf routes, the Baltic is narrow, shallow, and bordered by EU and North Atlantic Treaty Organization (NATO) states. Traffic density increases the probability of collision, and icy conditions in the winter reduce response time.
Moreover, the concentration of biodiversity in shallow waters raises ecological costs. A single spill could erase entire wintering grounds for migratory species. Commercial fisheries and coastal tourism risk sustained economic losses. Ageing, uninsured tankers operating in narrow and ecologically sensitive corridors create unmanaged environmental and economic exposure for EU and NATO states due to Russia’s refusal to meet international safety and liability standards.
A System Designed to Leverage Failure
Although the Shadow Fleet system was assembled to keep exports moving after sanctions, largely to help finance Russia’s war in Ukraine, it has become a durable logistics model that shirks liability and avoids traceability. The Fleet is also easy to abandon at the first sign of failure, given the already-aged nature of the ships and low experience levels of the crews that man them, suggesting low risk of detection or loss.
As use of the Shadow Fleet has transitioned into routine practice, the Shadow Fleet has clearly ceased to be a sanctions workaround and is now a deliberate tool of statecraft. The Shadow Fleet applies a form of irregular pressure on the EU and NATO that exploits systemic gaps without using overt force. Exploiters of this new paradigm have learned that they can thrive in such a system in which they can wield harm without attribution and systemically exploit enforcement gaps for maximum strategic benefit.
Operational Expansion, Systemic Spillover, and Failed Mitigation Efforts
The Shadow Fleet has evolved into a multi-state, multi-domain system that now intersects with Iranian operations, threatens critical ecosystems, provokes military confrontations, and tests the limits of existing maritime regulation. For example, operational overlap has formed between Russian and Iranian fleets. Multiple vessels have transported crude for both states. The Panama-flagged Themis, sanctioned by the UK, conducted voyages for both oil networks. UAE and Seychelles-based firms manage tankers linked to both regimes. They manage to get away with this through a mix of AIS manipulation, layered corporate ownership, and ship-to-ship transfers in jurisdictional blind spots.
Beyond ties to Iran, the Shadow Fleet’s operations are causing spillover in the High North, where Shadow Fleet-generated environmental risk has expanded into Norwegian waters. Non-ice-strengthened tankers have begun Arctic transit, raising contamination risks to coastal ecosystems. Norwegian fisheries, including salmon farms and cod grounds, face increased vulnerability from older vessels with unverifiable P&I coverage. Tanker density near Norwegian waters has increased twofold since 2023.
In some cases, kinetic protection has replaced deniability. On 13 May 2025, Estonia attempted to inspect the unflagged Jaguar in the Gulf of Finland. A Russian Su-35 fighter violated Estonian airspace in response. NATO aircraft responded under Baltic Air Policing protocols. This marked the first overt use of military force to shield a Shadow Fleet vessel. Five days later, Russia detained a Greek-owned tanker transporting Estonian fuel. Warships have since begun escorting select tankers through contested waters.
Regulatory responses remain reactive. On December 16, 2024, Nordic-Baltic states initiated joint insurance verification in key chokepoints including the Danish Straits and Gulf of Finland. Germany and Sweden began enforcement in mid-2025. Port authorities may now demand proof of P&I coverage and board non-compliant vessels. Yet compliance remains inconsistent. Existing frameworks allow documentation requests but lack real-time verification of insurer solvency, and over 20 percent of vessels refused disclosure in 2024.
Recommendations and Actions
The Shadow Fleet constitutes a coercive logistics system built on deniability, fragmented oversight, and regulatory asymmetry. Traditional interdiction tools are structurally misaligned with this environment. Effective disruption requires targeting the system’s support architecture such as registries, insurers, and intermediaries. Legal, financial, and administrative tools can impose compliance friction, restrict continuity, and constrain operational access without relying on physical interdiction.
Flag-state permissiveness enables the fleet’s legal maneuverability. Expansion of the Registry Information Sharing Compact (RISC) is required to establish reciprocal deregistration protocols among major open registries. Exposure of non-compliant registry metrics should be published monthly, ranking flag states by their concentration of high-risk vessels and triggering response thresholds at defined intervals. Jurisdictional pressure limits legal reflagging and strips operators of registry cover, signaling that permissive registries now carry reputational and operational cost, including escalating costs for cumulative non-compliance.
Insurance coverage must be verifiable at point of entry. The Nordic-Baltic 8 model should be adopted at all critical chokepoints, with port authorities authorized to demand real-time confirmation of P&I coverage. Solvency testing mechanisms for non-recognized insurers should be integrated into vessel clearance systems, and refusal to cooperate should constitute grounds for access denial. Port entry, then, receives restriction via solvency thresholds and insurer verification, and operators may now more directly face immediate operational costs.
Maritime sanctions enforcement must extend to ship management firms, staffing agencies, brokers, and corporate service providers that facilitate reflagging and ownership obfuscation. These entities should be designated based on open-source tracking of sanctioned vessel activity. Registries should mandate full disclosure of beneficial ownership as a precondition for registration, with independent audit capacity embedded in the review process. Disabling intermediaries severs access to registries, insurance, and reflagging pathways. Administrative disruption dismantles the redundancy that enables evasion across registries and ownership layers.
AIS manipulation and transshipment blind zones must be closed through persistent surveillance and enforced reporting. Satellite-AI tools including Windward classification models, Bellingcat Synthetic Aperture Radar (SAR) imagery, and Planet Labs optical data should be deployed in corridors with elevated evasion risk. Jurisdictions should require automatic reporting of AIS suppression lasting more than six hours in regulated zones. Detection of manipulation or repeated transmission gaps should trigger blacklisting and port exclusion under existing maritime safety authorities. Detection should trigger a sequence of exclusion protocols: flag revocation, port denial, and registry downgrade, all of which can scale, if needed, due to repeated violations.
Legal immunities must be narrowed to restore consequences, starting with amending the 1976 Limitation Convention to exclude vessels operating without verified P&I coverage. Bilateral recovery agreements must be developed between affected coastal states to enable legal compensation for cross-jurisdictional environmental harm. The mandate of the International Tanker Owners Pollution Federation (ITOPF) should be expanded to include coordination of cleanup and claims in cases involving stateless, abandoned, or unregistered vessels. Removing post-incident insulation makes liability enforceable at the structural level.
Conclusion
The Shadow Fleet is no longer a workaround for sanctions but a durable instrument of coercion, leveraging fragile ships, legal gaps, and opaque networks to shift risk onto others while serving Moscow’s strategic aims. If left unchallenged, it will normalize a maritime order where environmental disasters and economic disruption are routine costs, undermining security and stability in critical waterways. Mitigating this threat requires coordinated measures that close enforcement gaps, target enabling actors, and apply pressure across the fleet’s entire support system—not just on the vessels at sea. The system will persist until each administrative and financial layer of its architecture is denied operational freedom.
George Janjalia is a former Georgian Special Operations Forces and Military Intelligence officer with over a decade of experience in security and intelligence operations. He currently serves as Senior Country Security Manager for Healix International in Kyiv, Ukraine, where he oversees strategic risk management and operational security across a complex, high-threat environment. He is a graduate of The United States Military Academy.
Views expressed in this article solely reflect those of the author and do not reflect the official position of the Irregular Warfare Initiative, Princeton University’s Empirical Studies of Conflict Project, the Modern War Institute at West Point, or the United States Government.
Main Image: Image generated by ChatGPT using DALL·E, OpenAI (July 29, 2025).
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