In the context of Russia’s hybrid warfare activities, the concept of the shadow fleet is a matter of international law that needs to be addressed concerning maritime safety and security. After the 2022 Russian invasion of Ukraine, Western states introduced sanctions to curb Russia’s war revenue from oil and petroleum products. To circumvent these sanctions, Russia has resorted to fleets of ships with concealed ownership that are old and poorly maintained, also known as the shadow fleet. As will be examined in more detail in this article, these fleets disappear into the shadows by disabling their Automatic Identification System (AIS) and engage in illegal activities prohibited under international law. Although the shadow fleet is not a new concept, Russia’s activities in the Baltic Sea have given it a new dimension. Damage to submarine cables and pipelines has increased the security concerns of the states in the region, and thus the shadow fleet has become a critical issue for international organizations to address. This article examines how shadow fleet operations are carried out and what has been done by international organizations such as the International Maritime Organization (IMO), United Nations (UN), and European Union (EU).
1. Shadow Fleet Activity and Regional Security
What is the Shadow Fleet?
Shadow fleet is a growing challenge in maritime security and a threat to international regulation. Economic and political incentives play a crucial role in the proliferation of shadow fleet operations, such as the significant discounts on Russian crude oil, geopolitical alliances and flag of convenience[1]. Even though it is not a new phenomenon, since North Korea’s evasion of sanctions caused a template that is followed by other actors[2], it had to be addressed more thoroughly after the activities carried out by Russia in the Baltic Sea[3]. In a meeting held by Legal Committee of IMO to overcome this ongoing issue, The Committee defined a fleet of between 300 and 600 tankers primarily comprised of older ships, including some not inspected recently, having substandard maintenance, unclear ownership and a severe lack of insurance, was currently operated as a ‘dark fleet’ or ‘shadow fleet’ to circumvent sanctions and high insurance costs[4]. In other words, a shadow fleet is ships that are engaged in illicit activities while circumventing sanctions, evading compliance with safety or environmental regulations. The key concept of shadow fleet is to avoid detection so the vessels can operate in contravention of international norms and regulations. The operational strategies often indicate which of the two main divisions of the shadow fleet is operated under – dark fleet or gray fleet. By examining the differences between dark fleet and gray fleet, it can be understood why the realisation of unlawful acts of the shadow fleet concept cannot be detected and therefore shadow fleet turns into a clandestine feature of global maritime commerce.
Dark fleets often operate outside of the legal framework and engage in illegal activities by avoiding detection, manipulating of Automatic Identification System (AIS) transmitters, illicit ship to ship (STS) transfers, falsification of documentation and changing flags[5]. In the applications evaluated within the scope of dark fleet, the AIS which is used to determine the location and movements of the ship is manipulated by exploiting ‘innocent passage’ clauses in the UNCLOS[6]. Since AIS, which is designed for real-time tracking and providing information to other ships and the coastal state about the ship and even gives information about the position, course and speed of the ship, plays an essential role in ensuring maritime safety; this practice is also contrary to international maritime safety protocols[7] because it may lead to accidents[8]. Clandestine operations are not only carried out by switching off AIS transmitters, but also STS transfers in international waters where there is limited inspection is an effective way for evading sanctions[9]. Frequently changing flags to evade regulatory oversight is another way to escape from the international regulations while engaging in illegal activities, for example Russia’s shadow fleet regularly shifts registrations among ‘flag of convenience’ nations that do not enforce EU/G7+ sanctions which complicates monitoring the shipments[10]. Moreover, non-transparent ownership structures -complex networks of shell companies and offshore entities- make it difficult to enforce sanctions since opaque corporate arrangements serves to obscure their true ownership[11].
In comparison to dark fleets, gray fleets are at the edge of international law, exploiting legal loopholes while actually complying with regulations[12]. For instance, gray fleet vessels maintain active AIS transmitters thus, they appear to act in accordance with international maritime regulations, even though they may be involved in unlawful acts[13]. Facilitating oil-exports to non-sanctioning countries, such as Türkiye, China and India, before carrying them to their final destination is on the top of the unlawful acts[14].
Shadow Fleet in the Baltic Sea
The economic sanctions imposed against Russia after the invasion of Ukraine were aimed at cutting the revenues that had fuelled the war; therefore, the states supported an embargo on Russian oil imports by sea and a price cap on oil and oil products that would allow sales below a certain price while limiting profits[15]. Russia was also prevented from leasing and ensuring its tankers unless it agreed to comply with the restrictions[16]. On the contrary to expectations, Russia resorted to new markets and the shadow fleet method to overcome these limitations[17]. Since March 2022, Russia has been making intensive efforts to circumvent these sanctions mentioned above and according to the KSE report, Russia has invested US$10 billion in developing its shadow fleet to continue trading[18]. The Russian government has devised a number of ways to continue trading such as shifting tankers previously owned by Russian entities to new management companies, buying vessels over 15 years old from the cleared fleet because they were beyond the ‘insurance age’, using older ships to reduce financial risks that may appear in case of sanctions[19]. And these tactics give Russia a significant advantage, as its shadow fleet serves not only Russia but also other customers and is used for non‑sanctioned trade. Mary Melton, Freight Analyst at Vortexa, provided enlightening statistics on the amount of oil transported after the war, showing that Russia’s transports using grey fleet increased by %111 while dark fleet increased by %19[20].
Figure 1: Russian oil BPD moved using the gray fleet[21]
Figure 2: Russian oil BPD moved using the dark fleet[22]
As a result of the impositions of extensive Western sanctions after the invasion of Ukraine, Russia has increasingly relied on shadow fleet activities in the Baltic Sea to transport oil and other cargo covertly. Moreover, Russia’s oil export volume has been quite stable in the last 2.5 years, therefore, the price cap has managed to keep the Russian oil in the market and prevent any supply problems[23]. Especially China, Türkiye and India are the most important buyers, accounting for 60-70 per cent of exports through usage of shadow fleet[24].
The Russian shadow fleet is reported to be using a wide range of tactics like STS transfers, AIS blackouts, complicated ownership structures and flag hopping[25]. Many shadow fleet vessels in Russia’s shadow fleet use flags of convenience from countries that are unable to implement the sanctions of the West countries and frequently change flags of vessels which makes it difficult to detect Russian oil shipments. It is also observed that this process can be carried out using complex ownership structures and shell companies look like they are functioning in accordance with the law. Yet, in general, Russia’s shadow fleet is based on STS transfers, where Russian-origin oil is transferred many times before the ships reach their final destination which prevents the identification of the oil’s origin and makes it possible to evade inspection[26]. In addition, these vessels making STS transfers in international waters also avoid approaching ports in order to avoid the detection and even blend the Russian-origin oil with oils from other countries to make it harder to obscure its origin further[27]. When STS transfers are performed, AIS transmitters are switched off to conceal the illegality. According to Lloyd’s List Intelligence data, in August, an average of 164 cargo ships trading with Russia had their AISs corrupted per day, which is more than 1000 ships in a month[28]. As a result, the shadow fleet operations in the Baltic Sea have shown that this issue cannot be addressed at the national level alone, but also requires actions to be taken by international organizations.
2. The Role of International Organizations
In response to Russia’s reliance on shadow fleet activities, international measures are taken by the UN, IMO which does not impose sanctions but follows sanctions set by the UN Security Council or regionally by the EU.
Concepts such as information and influence operations -including psychological operations and propaganda- offensive cyber operations and electronic warfare, support to state and non-state partners, such as guerrillas and proxy forces, covert and clandestine actions by intelligence and special operations forces, including sabotage and subversion are currently defined under the term hybrid warfare, which refers to actions of states that do not reach the threshold of the war[29]. Shadow fleet is also considered within the scope of these activities and Russia has been using shadow fleet in its foreign policy in order to overcome the sanctions imposed by Western states to cut Russia’s revenue funded by Russian-origin oil transported by the sea[30]. In addition, shadow fleet has become a widely used instrument in Russia’s foreign policy, not only because it remains below conventional war limits, but also due to their low cost, plausible deniability[31]. In other words, due to the nature of hybrid warfare, it is difficult to impose sanctions against Russia, however, although hybrid warfare activities aim to remain below the concept of conventional warfare, they can be considered at the level of jus ad bellum in terms of some shadow fleet activities such as the Eagle S incident that occurred in December 2024[32]. At this point, Military and Paramilitary Activities in and against Nicaragua (Nicaragua v. United States of America) case, the judgement of the International Court of Justice in 1986 , is very important in defining the scope of use of force under Article 2(4) of the UN Charter[33]. “Scale and effects” standard that developed in this case can be used to interpret if sabotaging the cables and pipelines of a State using shadow fleet is an act of use of force[34] under the Article 2(4) which forbids all Member States in their international relations from threatening or using force against the territorial integrity or political independence of any state, or in any other manner inconsistent with the Purposes of the United Nations[35]. If a state is subjected to shadow fleet activity that could be considered within the scope of Article 2(4) of the UN Charter, the Charter allows self-defence under Article 51 until a decision is taken by the Security Council, whose decisions must be abided by all Member States[36].
According to the Charter of the United Nations, The Security Council is primarily responsible for maintaining international peace and security[37]. In this regard, the Security Council takes the lead in determining the existence of a threat to peace or an act of aggression and, as a further step, calls on the parties to the dispute to resolve it peacefully and proposes methods or terms of compromise[38]. In some cases, the Security Council may impose sanctions and even authorise the use of force in order to maintain or restore international peace and security[39]. The United Nations Security Council is empowered under the Chapter VII: Action with Respect to Threats to the Peace, Breaches of the Peace, and Acts of Aggression of the UN Charter to impose sanctions and take collective measures against the shadow fleet activities to maintain or restore international peace and security[40]. While in theory, this mechanism allows for a united international response, Russia’s veto power as a permanent member state of Security Council has effectively paralyzed the Council from taking any action since the beginning of its invasion of Ukraine[41]. As a result, the United Nations’ decision-making on the shadow fleet is limited to non-binding General Assembly resolutions, with Article 12 reserved[42].
EU, G7 and aligned countries have taken measures against Russia to counter its increased shadow fleet activities to continue oil exports[43]. The sanctions are aimed to apply on individual vessels and to increase international coordination in the combat with the shadow fleet. The EU has enacted special provisions against these activities as part of successive sanctions packages[44]. In the 11th package of sanctions, agreed in 2023, the EU prohibited the entry of vessels that involved in STS transfers suspected of violating the Russian oil import or the price cap or vessels deactivated AIS transmitters while carrying Russian-oil and oil products. In the continuing sanctions package adopted in 2024 it is intended to report the prices of tanker sales made by EU operators and thus to control the prices of sales to the third countries and ensuring market transparency[45]. The package also imposes an obligation on Member States to share information with one another and the European Commission, supported by the European Maritime Safety Agency about the shadow fleet activities that occur while transporting Russian-oil or petroleum products[46]. In the 14th package passed in June 2024, the list of the ships to be sanctioned as a result of Russia’s war on Ukraine was published and this list includes tankers involved in irregular and high-risk shipping practices in accordance with IMO General Assembly Resolution A1192(33)[47]. What should be emphasised is the answer given by Ms McGuinness on behalf of the European Commission to the question of what steps will the Commission take to manage economic, ecological and security policy risks posed by Russia’s activities in the Baltic Sea: “The Commission takes seriously the environmental and maritime safety risks posed by the dark fleet used by Russia to transport its oil. It is engaging at international level, including through the IMO and the International Oil Pollution Compensation Funds (IOPC Funds). The Commission and Member States worked together for the adoption of the ‘dark fleet’ resolution at the IMO in December 2023, which defines, for the first time, the dark fleet and sets out recommendations for coastal and flag states. The Commission is also working on measures to prevent unlawful practices associated with the fraudulent registration and fraudulent registries of vessels. EU sanctions are kept under constant review and can be expanded to achieve their objectives and address relevant challenges, including circumvention by nefarious actors involved in the shadow fleet. All EU restrictive measures are agreed by unanimity in the Council.[48]”
In response to the shadow fleet operations, the IMO has adopted several measures to strengthen the enforcement of regulations on maritime safety and environmental protection. During its 110th session, The Legal Committee of the IMO discussed the hazardous practice of STS transfers in the high seas, obscuring ship identities and turning off AIS transmitters[49]. The Committee called upon flag states to ensure that tankers under their flag comply with applicable IMO conventions, update STS operations manuals, and notify their flag State when engaged in mid-ocean operations[50]. Port States were also called upon to implement security and liability agreements, verify that STS operations meet security requirements, impose stricter controls on ships sailing under cover of darkness, and notify the relevant flag administrations[51]. Building on these discussions, in the IMO General Assembly Resolution A.1192(33) mentioned in McGuinness’ response, shadow fleet defined for the first time as ships that are engaged in illegal operations for the purposes of circumventing sanctions, evading compliance with safety or environmental regulations, avoiding insurance costs or engaging in other illegal activities, which may include:
- carrying out unsafe operations which do not adhere to international regulations and well-established and strict industry standards and best practices;
- intentionally avoiding flag State and port State control inspections;
- not maintaining adequate liability insurance or other financial security;
- intentionally avoiding commercial screenings or inspections; not operating under a transparent corporate governance policy that assures the welfare and safety of those on board and the protection of the marine environment;
- or intentionally taking measures to avoid ship detection such as switching off their AIS or LRIT transmissions or concealing the ship’s actual identity when there is no legitimate safety or security concern sufficient to justify such action[52].
Noting that shadow fleet vessels engaged in unlawful activities in order to avoid sanctions and inspections pose a serious and high risk to international maritime safety and environmental protection, the relevant authorities were urged to take measures against shadow fleet activities[53]. Lastly, on 14 January 2025, Secretary-General Arsenio Dominguez has emphasised that the shadow fleet is among the prominent issues in IMO’s 2025 Agenda and will be discussed in detail between 24-28 March 2025[54]. Also he stated technical cooperation and capacity-building will be provided to Member States for effective implementation of IMO regulations while encouraging all Member States to comply with their obligations as parties to IMO instruments in line with the Resolution A.1192(33)[55].
CONCLUSION
Although shadow fleets are not a new phenomenon, North Korea has long played a pioneering role in shadow fleet strategic operations. Yet, Russia’s shadow fleet operations in the Baltic Sea have shown that even seemingly insignificant illegal activities can quickly escalate and force international regulatory bodies to adapt. These developments show that it is crucial for international organisations not only to identify emerging threats but also to proactively close the legal loopholes that enable such activities to proliferate. Unfortunately, the current regulatory framework remains fragmented and insufficient in terms of both scope and enforcement capacity. This legal deficiency creates exploitable loopholes, enabling states like Russia to operate under the principle of deniability. Unfortunately, as long as the institutional structure of global maritime governance fails to address these weaknesses, shadow fleet tactics will continue to weaken collective security, environmental security and the rule of international law.
REFERENCES
Bridget Diakun, ‘Critical compliance tool compromised by GPS jamming’ (Lloyd’s List) <https://www.lloydslist.com/LL1150678/Critical-compliance-tool-compromised-by-GPS-jamming> accessed 7 June 2025
Caspar Hobhouse, ‘THE SHADOW FLEET: Time for action not reaction’ in Ondrej Ditrych and Steven Everts (eds), European Union Institute for Security Studies (EUISS, 2025) <http://www.jstor.org/stable/resrep70605> accessed 24 July 2025
Christian Schaller, ‘Sabotage of Submarine Cables and Pipelines as a Use of Force and Armed Attack’ (2025) <“Sabotage of Submarine Cables and Pipelines” by Christian Schaller> accessed 7 June 2025
Emilio Rodriguez-Diaz, Juan Ignacio Alcaide and Nieves Endrina, ‘Shadow Fleets: A Growing Challenge in Global Maritime Commerce’ (2025) <https://doi.org/10.3390/app15126424> accessed 24 July 2025
European Parliament, ‘Russia’s ‘shadow fleet’: Bringing the threat to light’ (2024) <Russia’s ‘shadow fleet’: Bringing the threat to light> accessed 24 July 2025
European Parliament, ‘The Russian shadow fleet in the Baltic Sea’ (2024) <Parliamentary question | The Russian shadow fleet in the Baltic Sea | E-001097/2024 | European Parliament> accessed 1 August 2025
International Maritime Organization, ‘Dark fleet, decarbonization and geopolitical pressures remain top maritime focus areas in 2025’ (14 January 2025) <Dark fleet, decarbonization and geopolitical pressures remain top maritime focus areas in 2025> accessed 1 August 2025
International Maritime Organization, Legal Committee (LEG 110), ‘Legal Committee, 110th session, (LEG 110) 27-31 March 2023’ <Legal Committee, 110th session, (LEG 110) 27-31 March 2023> accessed 24 July 2025
International Maritime Organization, Res A.1192(33) (6 December 2023) <https://wwwcdn.imo.org/localresources/en/KnowledgeCentre/IndexofIMOResolutions/AssemblyDocuments/A.1192%2833%29.pdf> accessed 1 August 2025
‘KSE Institute’s Russia Chartbook – Weaker Global Oil Prices Create An Opportunity To Exploit Vulnerabilities; Budget Reflects Commitment To War’ (Kyiv School of Economics, 2024) <KSE Institute’s Russia Chartbook – Weaker Global Oil Prices Create An Opportunity To Exploit Vulnerabilities; Budget Reflects Commitment To War – Kyiv School of Economics> accessed 7 June 2025
Military and Paramilitary Activities in and against Nicaragua (Nicaragua v United States of America) [1986] ICJ <https://www.icj-cij.org/case/70> accessed 1 August 2025
Security Council, United Nations Security Council <https://main.un.org/securitycouncil/en> accessed 1 August 2025.
Seth G Jones, ‘Russia’s Shadow War Against the West’ (2025) <http://www.jstor.org/stable/resrep68536> accessed 31 July 2025
Tomer Ranaan, ‘ ‘The Great Flag Exodus: Where Did Iran-Linked Ships Deflagged by Panama Go’ (2023) <https://www.lloydslist.com/LL1144047/The-great-flag-exodus-Where-did-Iran-linked-ships-deflagged-by-Panama-go> accessed 7 June 2025
United Nations, Charter of the United Nations, <https://www.un.org/en/about-us/un-charter/chapter-1> accessed 1 August 2025.
[1] Emilio Rodriguez-Diaz, Juan Ignacio Alcaide and Nieves Endrina, ‘Shadow Fleets: A Growing Challenge in Global Maritime Commerce’ (2025) < https://doi.org/10.3390/app15126424> accessed 24 July 2025
[2] ibid
[3] European Parliament, ‘Russia’s ‘shadow fleet’: Bringing the threat to light’ (2024) <Russia’s ‘shadow fleet’: Bringing the threat to light> accessed 24 July 2025
[4] International Maritime Organization, Legal Committee (LEG 110), ‘Legal Committee, 110th session, (LEG 110) 27-31 March 2023’ <Legal Committee, 110th session, (LEG 110) 27-31 March 2023> accessed 24 July 2025
[5] Emilio Rodriguez-Diaz, Juan Ignacio Alcaide and Nieves Endrina, ‘Shadow Fleets: A Growing Challenge in Global Maritime Commerce’ (2025) < https://doi.org/10.3390/app15126424> accessed 24 July 2025
[6] Caspar Hobhouse, ‘THE SHADOW FLEET: Time for action not reaction’ in Ondrej Ditrych and Steven Everts (eds), European Union Institute for Security Studies (EUISS, 2025) <http://www.jstor.org/stable/resrep70605> accessed 24 July 2025
[7] Emilio Rodriguez-Diaz, Juan Ignacio Alcaide and Nieves Endrina, ‘Shadow Fleets: A Growing Challenge in Global Maritime Commerce’ (2025) < https://doi.org/10.3390/app15126424> accessed 24 July 2025
[8] Caspar Hobhouse, ‘THE SHADOW FLEET: Time for action not reaction’ in Ondrej Ditrych and Steven Everts (eds), European Union Institute for Security Studies (EUISS, 2025) <http://www.jstor.org/stable/resrep70605> accessed 24 July 2025
[9] Emilio Rodriguez-Diaz, Juan Ignacio Alcaide and Nieves Endrina, ‘Shadow Fleets: A Growing Challenge in Global Maritime Commerce’ (2025) < https://doi.org/10.3390/app15126424> accessed 24 July 2025
[10] European Parliament, ‘Russia’s ‘shadow fleet’: Bringing the threat to light’ (2024) <Russia’s ‘shadow fleet’: Bringing the threat to light> accessed 24 July 2025
[11] Tomer Ranaan, ‘The Great Flag Exodus: Where Did Iran-Linked Ships Deflagged by Panama Go’ (2023) <https://www.lloydslist.com/LL1144047/The-great-flag-exodus-Where-did-Iran-linked-ships-deflagged-by-Panama-go> accessed 7 June 2025
[12] Emilio Rodriguez-Diaz, Juan Ignacio Alcaide and Nieves Endrina, ‘Shadow Fleets: A Growing Challenge in Global Maritime Commerce’ (2025) < https://doi.org/10.3390/app15126424> accessed 24 July 2025
[13] Emilio Rodriguez-Diaz, Juan Ignacio Alcaide and Nieves Endrina, ‘Shadow Fleets: A Growing Challenge in Global Maritime Commerce’ (2025) < https://doi.org/10.3390/app15126424> accessed 24 July 2025
[14] ibid
[15] European Parliament, ‘Russia’s ‘shadow fleet’: Bringing the threat to light’ (2024) <Russia’s ‘shadow fleet’: Bringing the threat to light> accessed 24 July 2025
[16] ibid
[17] ibid
[18] ibid
[19] ibid
[20] ‘UPDATED: Illuminating Russia’s Shadow Fleet’ (Windward, 2024) <Russia’s Shadow Fleet: 2024 Update on Tanker Tiers> accessed 24 July 2025
[21] ‘UPDATED: Illuminating Russia’s Shadow Fleet’ (Windward, 2024) <Russia’s Shadow Fleet: 2024 Update on Tanker Tiers> accessed 24 July 2025
[22] ibid
[23] Benjamin Hilgenstock, Yuliia Pavytska and Vira Ivanchuk, ‘KSE Institute’s Russia Chartbook – Weaker Global Oil Prices Create An Opportunity To Exploit Vulnerabilities; Budget Reflects Commitment To War’ (Kyiv School of Economics, 2024) <KSE Institute’s Russia Chartbook – Weaker Global Oil Prices Create An Opportunity To Exploit Vulnerabilities; Budget Reflects Commitment To War – Kyiv School of Economics> accessed 7 June 2025
[24] ibid
[25] European Parliament, ‘Russia’s ‘shadow fleet’: Bringing the threat to light’ (2024) <Russia’s ‘shadow fleet’: Bringing the threat to light> accessed 24 July 2025
[26] ibid
[27] European Parliament, ‘Russia’s ‘shadow fleet’: Bringing the threat to light’ (2024) <Russia’s ‘shadow fleet’: Bringing the threat to light> accessed 24 July 2025
[28] Bridget Diakun, ‘Critical compliance tool compromised by GPS jamming’ (Lloyd’s List) <https://www.lloydslist.com/LL1150678/Critical-compliance-tool-compromised-by-GPS-jamming> accessed 7 June 2025
[29] Seth G Jones, ‘Russia’s Shadow War Against the West’ (2025) <http://www.jstor.org/stable/resrep68536> accessed 31 July 2025
[30] ibid
[31] ibid
[32]Christian Schaller, ‘Sabotage of Submarine Cables and Pipelines as a Use of Force and Armed Attack’ (2025) <“Sabotage of Submarine Cables and Pipelines” by Christian Schaller> accessed 7 June 2025
[33] Military and Paramilitary Activities in and against Nicaragua (Nicaragua v United States of America) [1986] ICJ <https://www.icj-cij.org/case/70> accessed 1 August 2025
[34] Christian Schaller, ‘Sabotage of Submarine Cables and Pipelines as a Use of Force and Armed Attack’ (2025) <“Sabotage of Submarine Cables and Pipelines” by Christian Schaller> accessed 7 June 2025
[35] United Nations, Charter of the United Nations, art. 2(4) <https://www.un.org/en/about-us/un-charter/chapter-1> accessed 1 August 2025
[36] United Nations, Charter of the United Nations, art. 51
<https://www.un.org/en/about-us/un-charter/chapter-7> accessed 1 August 2025
[37] United Nations Security Council, Security Council <https://main.un.org/securitycouncil/en> accessed 1 August 2025.
[38] United Nations Security Council, Security Council <https://main.un.org/securitycouncil/en> accessed 1 August 2025
[39] ibid
[40] United Nations, Charter of the United Nations, art. 39-51 <https://www.un.org/en/about-us/un-charter/chapter-7> accessed 1 August 2025.
[41] United Nations, Charter of the United Nations, art. 23-32 <https://www.un.org/en/about-us/un-charter/chapter-5> accessed 1 August 2025.
[42] United Nations, Charter of the United Nations, art. 33-38 <https://www.un.org/en/about-us/un-charter/chapter-4> accessed 1 August 2025
[43] European Parliament, ‘Russia’s ‘shadow fleet’: Bringing the threat to light’ (2024) <Russia’s ‘shadow fleet’: Bringing the threat to light> accessed 24 July 2025
[44] European Parliament, ‘Russia’s ‘shadow fleet’: Bringing the threat to light’ (2024) <Russia’s ‘shadow fleet’: Bringing the threat to light> accessed 24 July 2025
[45] European Parliament, ‘Russia’s ‘shadow fleet’: Bringing the threat to light’ (2024) <Russia’s ‘shadow fleet’: Bringing the threat to light> accessed 24 July 2025
[46] ibid
[47] ibid
[48] European Parliament, ‘The Russian shadow fleet in the Baltic Sea’ (2024) <Parliamentary question | The Russian shadow fleet in the Baltic Sea | E-001097/2024 | European Parliament> accessed 1 August 2025
[49] International Maritime Organization, Legal Committee (LEG 110), ‘Legal Committee, 110th session, (LEG 110) 27-31 March 2023’ <Legal Committee, 110th session, (LEG 110) 27-31 March 2023> accessed 24 July 2025
[50] International Maritime Organization, Legal Committee (LEG 110), ‘Legal Committee, 110th session, (LEG 110) 27-31 March 2023’ <Legal Committee, 110th session, (LEG 110) 27-31 March 2023> accessed 24 July 2025
[51] ibid
[52] International Maritime Organization, Res A.1192(33) (6 December 2023) <https://wwwcdn.imo.org/localresources/en/KnowledgeCentre/IndexofIMOResolutions/AssemblyDocuments/A.1192%2833%29.pdf> accessed 1 August 2025
[53] ibid
[54] International Maritime Organization, ‘Dark fleet, decarbonization and geopolitical pressures remain top maritime focus areas in 2025’ (14 January 2025) <Dark fleet, decarbonization and geopolitical pressures remain top maritime focus areas in 2025> accessed 1 August 2025
[55] ibid