Europe’s shadow fleet problem is really about governance at sea

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Europe’s shadow-fleet standoff isn’t just a sanctions story. It’s a stress test for the rules that make global shipping work: flags, insurance, and who pays when something goes wrong. In the Baltic Sea, coastguards can talk to tankers and monitor them — but stopping them is legally and politically hard.

What’s emerging, according to reporting from the BBC in November 2025, is an escalation in both scale and ambiguity: more “shadow” vessels, more frequent flag changes, and a growing number of tankers sailing without a valid national flag at all.

Why the “shadow fleet” exists in the first place

After Russia’s full-scale invasion of Ukraine, Western countries imposed sanctions on Russian energy. One key idea was a price cap on Russian oil exports: let oil keep moving (to avoid a global supply shock), but restrict the revenue Russia could earn per barrel.

In practice, a cap like that creates an obvious incentive: keep exporting, but route cargo and paperwork through channels that make enforcement harder.

The BBC describes the “shadow fleet” as hundreds of tankers used to bypass the price cap on Russian oil exports. These ships tend to share a few traits that make scrutiny and accountability difficult:

  • They are often older vessels.
  • Ownership is opaque and sometimes routed through shell companies.
  • Insurance arrangements can be unclear.
  • Ships may change names and flags frequently, while keeping the same unique IMO number.

That last point matters. A name and a flag are human-facing labels. The IMO number is what ties the vessel’s identity together across time.

Flags, “false flags”, and what “stateless” really means

A ship’s flag isn’t decoration. It’s a legal relationship: the flag state is responsible for regulating the vessel, setting standards, and (in theory) enforcing rules.

The BBC reports a “growing network” of shadow ships sailing without a valid national flag, a situation that can leave vessels effectively stateless — and potentially without proper insurance.

A stateless vessel is a special problem because it sits in a grey zone. The “right of innocent passage” is a cornerstone of maritime law, but the BBC notes stateless vessels technically are not entitled to it.

Even that doesn’t instantly translate into easy enforcement. Countries still have to weigh:

  • What they can legally do in their waters versus on the high seas.
  • What evidence is strong enough to justify detention.
  • Whether action could trigger retaliation or escalation.

The BBC cites International Maritime Organization (IMO) data showing the number of falsely flagged ships globally more than doubled in 2025 to over 450 — most of them tankers.

That figure is telling for two reasons. First, it suggests this is no longer a fringe tactic. Second, it hints at a global compliance capacity problem: even if regulators want to police flags rigorously, the volume is rising.

The Unity case: a ship’s identity in motion

To make the abstraction real, the BBC tracks one ship: the tanker Unity.

From the article:

  • The ship was built in 2009.
  • It was originally known as Ocean Explorer and flew the Singapore flag for more than a decade.
  • By late 2021 it took the flag of the Marshall Islands, but was struck from that registry in 2024 after the UK sanctioned the ship’s then-operator and beneficial owning company, according to a registry spokesperson.
  • Since 2021, it appears to have had three further names (Beks Swan, March, Unity) and three further flags (Panama, Russia, Gambia) while retaining the same unique IMO number.
  • In August, broadcasting data showed Unity claiming the flag of Lesotho, which the BBC says was designated “false”; the IMO does not list Lesotho as having an official registry.

The BBC also reports that Unity passed through the English Channel four times in the previous 12 months, including journeys between Russian ports and India — a key oil customer that has not signed up to the price cap.

By late October it sailed into the Baltic and by 6 November it was anchored outside the Russian oil port of Ust-Luga, where it remained at the time of publication.

This “identity in motion” is not a quirky detail. It’s a tactic with operational benefits:

  • It increases friction for enforcement: every rename or reflag forces investigators to rebuild context.
  • It complicates liability: if ownership and insurance are unclear, who pays after an accident becomes a fight.
  • It raises safety risk: ships that fall out of reputable registries may also fall out of stricter maintenance and oversight regimes.

Why insurers and registries become the choke points

If sanctions were easy to enforce at sea, the job would be simple: stop a tanker, inspect the cargo, verify compliance.

But shipping isn’t built around routine interdiction. It’s built around paperwork and trust:

  • Registries define who the ship “belongs” to legally.
  • Insurers define who will pay if something goes wrong.
  • Classification, inspections, and port-state controls provide periodic checks.

When a ship operates with obscure ownership and questionable flag status, those trust anchors weaken.

A senior maritime intelligence analyst at Windward AI, Michelle Wiese Bockmann, tells the BBC that many shadow ships are “floating rust buckets”. Her point is blunt: if there is an accident like a billion-dollar oil spill, “good luck with trying to find somebody responsible to pick up any cost”.

That’s the core strategic problem for coastal states. A single major spill in a narrow, busy body of water is both an environmental crisis and a political crisis — and it is hard to price or insure if the responsible parties are hidden.

What “monitoring” can and can’t do in the Baltic

The BBC joined Swedish coastguards in the western Baltic as officers radioed a nearby sanctioned tanker and gathered information: insurance details, flag state, last port of call (Suez, Egypt). The whole exchange lasted a little over five minutes.

To a reader, that can feel underwhelming — a polite call to a ship that continues toward Russia.

But it illustrates how deterrence often looks in mature legal systems: collection of verifiable facts, not immediate confrontation.

A Swedish investigator, Jonatan Tholin, explains why this still matters: the information can be used in maritime surveillance.

Estonia’s perspective adds the geopolitical constraint. Commodore Ivo Värk, head of Estonia’s navy, says vessels travel back and forth past Estonia to major Russian oil terminals at Ust-Luga and Primorsk. He says Estonia has seen dozens of such passing vessels in 2025, whereas it used to see just one or two.

And when Estonia attempted to intercept a flagless tanker in May, Commodore Värk says Russia briefly deployed a fighter jet — after which Russia has “constantly” kept about two naval vessels in the Gulf of Finland.

This is the trade-off in one scene:

  • Stronger enforcement might reduce risk.
  • Stronger enforcement might also raise the risk of escalation.

The money keeps flowing — and that shapes everything

Sanctions are about changing incentives. The question is whether the new costs (risk, friction, lost access to services) outweigh the revenue.

The BBC cites the International Energy Agency (IEA): Russian revenues from crude and oil product sales were $13.1bn (£9.95bn) in October 2025, down by $2.3bn compared with the same month a year earlier.

It also cites analysis by the Centre for Research on Energy and Clean Air, which finds that shadow tankers — either sanctioned or suspected — account for 62% of shipped Russian crude oil exports. The same analysis says China and India are by far the biggest customers for crude, followed by Turkey and the European Union itself.

Those numbers matter because they explain why shadow-shipping tactics persist:

  • The revenue remains large enough to justify complex workarounds.
  • The customer base includes major economies that can absorb risk.
  • The flow is global, but the environmental and security risk is concentrated in chokepoints like the Baltic.

The bigger pattern: rules-based order, tested by logistics

There’s a line near the end of the BBC piece that frames the story beyond oil: “You can literally see the international rules-based order crumbling through the sanctions-circumventing tactics of these vessels,” Michelle Wiese Bockmann says.

That sounds dramatic, but the mechanism is practical.

The modern shipping system depends on layered institutions — registry, insurance, port controls, shared conventions — that make it possible for ships to cross borders without being treated as a constant security threat.

When a large volume of trade migrates to actors willing to:

  • operate with unclear flags,
  • churn ownership,
  • accept lower safety standards,
  • and treat compliance as optional,

the “baseline trust” in the system erodes. Coastal states then face pressure to respond with more monitoring and more enforcement.

But more enforcement is expensive and politically risky, especially when the other side is a nuclear-armed state operating near your borders.

Bottom line

The shadow fleet is not just a workaround for an oil price cap. It’s a growing governance gap — and the risk is that the bill arrives as an oil spill, an infrastructure incident, or a sudden escalation at sea.

Sources

n English