Sanctions SOS’ Post

On 27 November, Lloyd's List published an article arguing that current sanctions on Russia’s 'shadow fleet' are not sufficiently disrupting oil flows or war financing. The article suggests that, while 100s of vessels and shipowners have been sanctioned, Russian oil continues to move widely, largely redirected to Asian markets. Rather than disrupting Russia's economy, the strategy has contributed to the growth of a parallel 'sanctioned economy' that operates alongside legitimate trade. Russia’s trade surplus peaking in 2024 is named as evidence that vesself-focused enforcement has not delivered the intended impact. A challenge identified is the lack of a clear definition of what the 'shadow fleet' actually is. Lloyd’s List proposes one of the most workable approaches to date, defining a shadow fleet tanker as a vessel that engages in deceptive shipping practices linked to sanctioned oil from Russia, Iran or Venezuela, is itself sanctioned for involvement in illicit oil trades, is connected to a sanctioned company, or participates in a cargo chain where deceptive practices occur at any point. The authors argue that without a clear definition that port officials and operators can apply in real time, enforcement will continue to fall short. As opposed to focusing mainly on ships, the article calls for a shift to ports as the pressure point. This makes logical sense: when vessels can't access ports, they can't trade. States already have the sovereign right to refuse port entry, but this power is underused in the context of shadow fleet activity. Targeting ports that routinely service these vessels could deter cooperation and raise the commercial/political cost of facilitating Russian oil exports. The authors also point to port compliance mechanisms like the ISPS Code as another enforcement route. Declaring ports that service shadow fleet vessels as non-compliant could restrict their access to insurance and global trade networks, discouraging legitimate operators from engaging with them. While maritime sanctions have become a popular tool, the article concludes that real impact will only come when enforcement moves closer to the port. This, the authors argue, is where compliance, regulation and accountability are more practical and enforceable. 🟣 Sanctions SOS perspective In line with this discussion, sanctions evasion moves beyond financial transactions: it is now increasingly about assessing risk in logistics, trade routes, and physical infrastructure. For businesses operating in shipping, commodities, insurance or trade, grasping port risk and shipment behaviour is now as important as screening counterparties. Sanctions SOS supports organisations in identifying exposure, assessing risk, and building compliance frameworks that adapt to emerging evasion tactics and changing regulatory expectations. 📩 Contact us today: enquiries@sanctionssos.com #russiasanctions #shadowfleet #maritimerisk #compliance