Maritime Sanctions Taskforce

RUSI’s Maritime Sanctions Taskforce first convened in November 2024, to assess the threats posed by Russia’s circumvention of maritime sanctions, in particular through its shadow fleet, and to identify enforcement priorities for G7+ partners. The findings from this inaugural meeting were reflected in the first Taskforce report.

In January 2025, the Taskforce held its second meeting, to examine the evolving strategies of the shadow fleet and provide operational recommendations to enhance collective enforcement efforts. The discussion addressed the shifting patterns of the shadow fleet, the need to refine designations, the importance of diplomatic engagement with flag states, and the potential leverage of international legal frameworks to strengthen maritime sanctions enforcement. This report summarises the findings and recommendations of the second Taskforce meeting, in order to inform policy decisions, enhance international coordination, and bolster the effectiveness of maritime sanctions.

Contributions from Taskforce members are made on an unattributable basis and this summary report does not necessarily represent the views of all Taskforce members.

Update on the Shadow Fleet’s Shifting Patterns

The Taskforce began by assessing recent shifts in shadow fleet routes and operational methods. Participants highlighted that the fleet is evolving in response to ongoing enforcement measures and heightened regional coordination efforts by Nordic and Baltic states and other G7+ countries. The ability to accurately track these changes is key to ensuring the continued effectiveness of monitoring and enforcement efforts.

While the term “shadow fleet” is often used broadly, some Taskforce members distinguished three main categories:

• The cleared fleet, consisting of vessels with no suspicious activity or opaque ownership structures;

• The grey fleet, comprising vessels operating within legal ambiguities and/or benefiting from weak regulatory oversight, but not necessarily violating sanctions outright;

• The dark fleet, which includes vessels engaged in clear illicit activity, such as deceptive shipping practices, fraudulent cargo documentation and false flagging.

According to this categorisation, some Taskforce members shared their observations based on active tracking of the maritime domain. They noted an increase in the size of the grey fleet following the new measures introduced by the US sanctions package of 10 January 2025. The dark fleet, however, has remained relatively stable, with an estimated 1,600 vessels continuing to engage in illicit activity operations. According to some Taskforce members, the core fleet dedicated to Russia’s shadow oil trade currently comprises approximately 350 tankers without International Group of Professional and Indemnity Clubs (IGP&I) insurance and with opaque ownership structures. Unlike the activity of some other global shadow fleet operations, such as those servicing Iran or Venezuela, Russian vessels still need to transit strategic chokepoints such as the Danish and Turkish Straits, making it difficult for them to operate entirely unnoticed.

Participants also highlighted the emergence of new hubs for shadow fleet activity, most notably in Brazil and the Arctic Sea. Moreover, there has been a marked increase in the manipulation of Global Navigational Satellite System (GNSS) or location tampering as means of evading detection.

The Taskforce agreed that the 10 January sanctions package had led to a significant shift in vessel behaviour. Notably, there was a sharp increase in vessels drifting in the South China Sea and a rise in ship-to-ship transfers occurring in more remote anchorage locations. These changes highlight the shadow fleet’s adaptability in response to regulatory actions and further emphasise the need for sustained vigilance.

Additionally, Taskforce members from the protection and indemnity (P&I) insurance community commented on the recent uplift of the carriage of 2707 cargoes from Russia. Some members had observed in trade data that cargo corresponding to Harmonized System (HS) code 2707 – that is, oils and other products of the distillation of high temperature coal tar – are increasingly being reported as exports from Russia. 2707 cargoes are not subject to the Oil Price Cap (OPC), unlike oil and petroleum cargo matching codes 2709 or 2710.

Defining the Shadow Fleet

Participants noted that a clear definition of the shadow fleet is necessary to underpin legal and enforcement actions. The International Maritime Organization (IMO) defines the shadow fleet 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:

1. carrying out unsafe operations which do not adhere to international regulations and well-established and strict industry standards and best practices;

2. intentionally avoiding flag State and port State control inspections;

3. not maintaining adequate liability insurance or other financial security;

4. intentionally avoiding commercial screenings or inspections;

5. 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

6. intentionally taking measures to avoid ship detection such as switching off their AIS [Automatic Identification System] or LRIT [long-range identification and tracking] transmissions or concealing the ship’s actual identity when there is no legitimate safety or security concern sufficient to justify such action”.

Lloyd’s List offers a complementary definition, categorising a tanker as part of the “dark fleet” if it is “aged 15 years or over, anonymously owned and/or has a corporate structure designed to obfuscate beneficial ownership discovery, solely deployed in sanctioned oil trades, and engaged in one or more of the deceptive shipping practices outlined in US State Department guidance issued in May 2020.”

The Kyiv School of Economics offers a broader definition, arguing that the shadow fleet comprises “all vessels that simultaneously meet two conditions: They lack Western insurance coverage as they rely on providers outside of the International Group of P&I Clubs … They are owned and managed by companies not from G7/EU countries.”

The Taskforce concluded that the IMO definition remains the most viable, as it provides a legal foundation for tracking and targeting shadow fleet activity by an internationally recognised multilateral body. A universally accepted definition will enable greater consistency of enforcement actions, reducing the risk of ambiguity and ensuring that shadow fleet vessels are subjected to uniform scrutiny across jurisdictions.

Refining Designations for Maximum Impact

The Taskforce debated how to refine vessel designations to ensure that sanctions remain effective while preventing unintended economic consequences. The pace of vessel designations has accelerated, with a sharp increase in deep-sea vessels designated over the past year, yet concerns persist about the clarity, consistency and long-term implications and sustainability of these designations.

In this context, the Taskforce considered expanding designation targets beyond vessels towards maritime facilitators. This would explicitly exclude individual seafarers, as it was widely agreed that targeting ship crews would be ineffective and ethically questionable, since they often lack decision-making power and have little choice but to accept employment on sanctioned vessels. Instead, Taskforce members advocated for designating ship management companies (including those offering crew management and technical management services) and other intermediaries that knowingly facilitate shadow fleet activities. The decision by Chinese ports in Shandong to refuse berthing to US-sanctioned vessels just ahead of the 10 January sanctions package might signal that direct pressure on port operators could be an effective mechanism for curtailing shadow fleet activity.

Flag registries also came under scrutiny, with some members noting that many registries remain unaware of the risks associated with accepting shadow fleet vessels. By targeting the infrastructure that supports illicit shipping, including through greater engagement with flag states and the services companies that manage many of their registries, enforcement efforts could be not only more effective, but also less disruptive to innocent parties. This is explored in greater depth below.

The Taskforce explored the unintended consequences of aggressively driving vessels out of regulated systems. While strict enforcement is essential, some participants warned that pushing shadow fleet vessels further into opaque, unregulated markets could exacerbate risks rather than mitigate them. When vessels lose access to legitimate insurance, classification societies and flag registries, they often resort to clandestine operations with reduced oversight, increasing the likelihood of fraudulent documentation, illicit trading and maritime safety violations. This creates a regulatory blind spot where these vessels continue to operate under even riskier conditions, heightening environmental and security concerns. The Taskforce discussed the need for a balanced approach that targets bad actors while maintaining enough oversight to prevent a complete loss of regulatory control over shadow fleet operations.

Some Taskforce members suggested the possibility of an advisory or probationary list for flag registries that demonstrate a pattern of registering vessels engaged in illicit activities, following advisories from the US Office of Foreign Assets Control (OFAC) and, more recently, Taiwan. While such measures would need to be carefully designed to avoid overreach, they could serve as a useful tool in encouraging higher compliance standards across the industry. However, the listing of vessels without imposing formal sanctions raised concerns among some Taskforce members, who highlighted the need for more robust and clear designation criteria.

The US has demonstrated a more precise approach, providing detailed justifications for vessel listings. By contrast, the UK and the EU have relied on broader, less specific statements, often citing general involvement in the Russian oil trade without clearly outlining whether vessels have violated the OPC, are Russian-owned, or have engaged in deceptive shipping practices. Taskforce members discussed the fact that this lack of transparency creates uncertainty in the market, making it difficult for insurers, shipowners and financial institutions to determine compliance requirements and assess risk accurately. Regulators have the tools and intelligence necessary to refine this process, and greater transparency in the designation process would enable industry stakeholders to adjust their risk management frameworks accordingly and achieve stronger adherence to maritime sanctions.

Another key issue discussed was the potential for a structured delisting mechanism for vessels that demonstrate compliance or seek to reintegrate into legitimate trade. Some Taskforce members argued that an expedited delisting process could incentivise vessels to cease shadow fleet operations and return to the mainstream fleet, provided they meet stringent compliance criteria. The notion of allowing vessels to correct their behaviour and regain access to legitimate markets was seen as a potential means of encouraging compliance, rather than forcing vessels further into the illicit market. However, scepticism remains regarding whether such a system could be effectively implemented.

Some industry representatives expressed reluctance to reintegrate vessels that have a history of sanctions evasion. Reputable shipowners and insurers posit that vessels that have profited from sanctions violations should not be allowed to re-enter the legitimate market without significant scrutiny. Allowing such vessels to return to normal operations without facing penalties might risk encouraging others to engage in similar violations, with the expectation that they could later return to compliant trade with little consequence. This resistance from some actors in the insurance and shipping industries highlights the challenge of designing a delisting framework that balances the need for deterrence with the potential benefits of encouraging vessels back into compliance.

The long-term implications of prolonged vessel designations complicate matters further. Some Taskforce members noted that, without a viable delisting mechanism, sanctioned vessels could eventually be abandoned, creating serious environmental and humanitarian hazards. When shipowners realise that their vessels are permanently excluded from the mainstream market, they may choose to scrap or neglect them, increasing the risk of oil spills, maritime accidents, and seafarer abandonment. This issue is particularly pressing given that many vessels operating within the shadow fleet are approaching or beyond the end of their operational lifespan. Without a structured means of decommissioning or scrapping these vessels, there is a growing risk of a buildup of obsolete tankers that are both environmentally hazardous and legally problematic for insurers.

A final consideration discussed was the need for improved collaboration between regulatory authorities and the private sector. Participants noted that in the US, the White House, the US State Department and the US Treasury Department are reportedly exploring the establishment of specialised maritime desks dedicated to addressing Russian and Iranian sanctions. Taskforce members suggested that, if these efforts materialise, a formal government–private sector partnership could prove invaluable to streamlining enforcement efforts. This would facilitate the dialogue between policymakers and industry experts, with a partnership that could improve information sharing, enhance due diligence processes, and develop more effective strategies for addressing illicit shipping practices.

Strengthening Engagement with Flag States

As noted above, the Taskforce agreed that engagement with flag states remains a critical element in enforcing maritime sanctions and limiting the operations of the shadow fleet. Flag states enable vessels to operate internationally, granting them the necessary legal status to navigate global waters. This makes them a pivotal point of leverage for policymakers seeking to reinforce compliance measures. While flag states retain sovereign control over their registries, participants noted that many remain unaware of the reputational risks associated with facilitating illicit shipping activities.

The relationship between flag states and their registries varies considerably, which influences how receptive flag states are to diplomatic engagement. Some countries, such as Panama, for example, maintain direct governmental oversight of their registries, integrating them into national maritime policy and economic strategy. Others, such as Gabon, outsource their registries to private entities (in the case of Gabon, located in the UAE) that operate with minimal governmental involvement. Panama, the world’s second-largest flag registry, has demonstrated a willingness to enhance compliance measures following leadership changes and strategic diplomatic outreach, leading to the deregistration of several sanctioned vessels. Liberia, the world’s largest registry, has also engaged in constructive discussions with enforcement authorities, and participants shared that the country is in the process of formalising a memorandum of understanding with the UK to bolster transparency and cooperation in flagging policies.

According to government officials, the UK’s diplomatic approach has prioritised what is commonly referred to as “carrot and stick” diplomacy, with a strong emphasis on incentives rather than just on coercion. This strategy involves understanding the economic aspirations of flag states and their strategic interests within the IMO. Recognising that many flag states do not explicitly align themselves with Western geopolitical interests, UK officials have instead focused on highlighting the long-term economic and reputational benefits of maintaining high compliance standards. Flag registries that cultivate a reputation for professionalism and reliability stand to gain broader access to mainstream shipping markets, whereas those associated with illicit activities risk being marginalised.

Some Taskforce members added that a key aspect of this progress has been leveraging competition between flag registries. Countries such as Panama and Liberia compete vigorously for market share in the global registry business. This rivalry presents an opportunity to encourage better regulatory standards, as each seeks to position itself as the preferred choice for legitimate shipowners. For instance, Panama’s decision to deregister vessels associated with the Russian shadow fleet was influenced in part by concerns about being outflanked by Liberia in the registry business, according to participants.

However, engagement has yielded mixed results with newer registries that have emerged as key enablers of shadow fleet operations. Gabon, for instance, has played an increasingly prominent role in registering Russian-linked vessels, particularly following the delisting of Sovcomflot tankers in Liberia. The Gabonese registry began registering Russian oil tankers in late 2023, rapidly expanding its presence in the shadow fleet sector. Diplomatic efforts have focused on encouraging Gabon to reconsider its role in facilitating illicit shipping, and there have been some positive signals, though results remain inconclusive. Similarly, Cameroon’s registry has been identified as a growing concern, requiring further engagement to determine whether it can be persuaded to adopt stronger compliance measures.

However, the economic incentives for some flag states to maintain lax oversight remain a significant barrier to enforcement. Many registries derive substantial revenue from vessel registrations and are hesitant to impose stricter controls that could deter business. Addressing this challenge requires a multifaceted approach that not only emphasises reputational risks but also explores ways to provide alternative economic incentives for compliance. Thus, the Taskforce agreed that one of the key lessons from diplomatic engagement has been the effectiveness of framing discussions around environmental and safety concerns, rather than directly addressing the shadow fleet. Flag states often respond more positively to arguments highlighting the risks posed by substandard vessels to marine ecosystems and maritime safety than to discussions explicitly tied to sanctions enforcement. This approach has proven particularly useful in encouraging deregistration efforts, as flag states can justify compliance actions based on broader regulatory concerns, rather than on political alignment.

Another critical aspect of flag state engagement involves the interconnected nature of regulatory enforcement. Flag registries do not operate in isolation, but are part of a broader ecosystem that includes insurers, classification societies and financial institutions. Taskforce members discussed the diplomatic engagement which has sought to connect these dots, ensuring that actions taken against shadow fleet vessels trigger cascading consequences that reinforce compliance across multiple sectors. For instance, vessels that lose their flag status often face difficulties securing insurance and financing, creating a compounding effect that increases the cost of illicit operations.

Despite progress in some areas, the rapid reflagging of shadow fleet vessels from one jurisdiction to another underscores the adaptability of illicit operators. Participants agreed that efforts to deregister sanctioned vessels must be accompanied by measures to prevent them from simply shifting to another accommodating flag. This “Whac-a-Mole” dynamic highlights the need for sustained engagement and ongoing monitoring to ensure that flag states do not simply replace deregistered vessels with new ones linked to the same illicit networks. Moving forward, G7+ partners must continue strengthening partnerships with flag states that have demonstrated a commitment to compliance, while increasing pressure on non-cooperative registries to achieve impactful measures against the shadow fleet’s illicit shipping activities.

Leveraging International Frameworks and Institutions

The Taskforce examined the role of existing international frameworks in addressing the challenges posed by the shadow fleet, with a particular focus on the UN Convention on the Law of the Sea (UNCLOS). Participants emphasised that any enforcement measures must align with the rules-based international order to maintain legitimacy and avoid unintended consequences. However, discussions underscored the growing complexity of applying traditional legal instruments to contemporary threats, particularly as other states are increasingly weaponising vessels in hybrid warfare and ignoring longstanding global norms and standards.

A key concern was the legal interpretation of UNCLOS, which enshrines fundamental principles such as innocent passage and transit rights through international straits. These rights are not contingent upon a vessel’s ownership structure, insurance status or compliance history, posing a challenge for enforcement efforts. Some Taskforce members argued that a rigid interpretation of UNCLOS limits the ability of states to respond to emerging security threats – particularly as adversarial actors exploit these provisions to evade scrutiny – and argued for an evolution of international law and standards. Others cautioned against attempts to stretch UNCLOS beyond its intended scope, warning that such actions could establish precedents that adversarial states might use to justify their own violations of international maritime law.

Notably, sanctions enforcement – particularly when not resulting from a decision at the UN – remains outside the explicit remit of UNCLOS, as such action is inherently a political tool wielded by individual states, rather than a globally mandated mechanism. Some participants stressed that attempts to use UNCLOS as an enforcement vehicle for sanctions could undermine its credibility, particularly given that the convention was not designed to regulate economic restrictions. Others pointed out that while direct sanctions enforcement is not within UNCLOS’s scope, broader principles of maritime security and environmental protection could be leveraged to address the shadow fleet’s activities.

The increasing use of civilian vessels in hybrid warfare adds another layer of complexity. Recent instances of suspected undersea cable sabotage, potentially linked to shadow fleet operations, have heightened concerns about maritime security. While the deliberate severing of cables constitutes a hostile act, proving intent remains challenging. Representatives from the P&I community noted that cable-severing incidents are common, with accidental damage occurring regularly due to anchor drags and fishing activity. The challenge, therefore, lies in distinguishing between genuine accidents and deliberate acts of aggression. Existing conventions, such as the 1884 Convention for the Protection of Submarine Telegraph Cables, were not designed to address such hybrid threats. Under this framework, if a country discovers a Russian vessel interfering with cables, the prescribed legal procedure involves collecting evidence and referring the matter to Russia for action – an entirely unrealistic scenario given current geopolitical tensions.

This legal ambiguity presents a dilemma: while enforcement efforts must remain within established legal frameworks, the existing conventions do not adequately address emerging threats. The Taskforce debated whether it would be possible to introduce an evolutionary interpretation of UNCLOS, incorporating evolving security concerns. Some Taskforce members argued that, under the Vienna Convention on the Law of Treaties, the interpretation of international law can be dynamic. Indeed, UNCLOS provisions have been revisited in other contexts, such as environmental protection, to reflect new developments. However, others stressed the risks of this approach, warning that novel legal interpretations could invite retaliatory actions from states that might also exploit such precedents for their own strategic purposes.

A related challenge identified by the Taskforce was the lack of transparency in flag state oversight of vessel insurance. Many designated vessels do not publicly disclose their insurance coverage, relying instead on self-reported compliance. This raises significant concerns, as incidents, such as the Alpha I tanker spill in Greece, have demonstrated the risks of inadequate insurance coverage for sanctioned vessels. IMO guidelines on insurance disclosures remain non-mandatory, and efforts to strengthen these regulations have met resistance from certain flag states. Participants debated whether the IMO could be leveraged to introduce stronger disclosure requirements for tanker insurance, compelling insurers to provide verifiable information on capital adequacy and financial transparency. This, in turn, could improve risk assessment and reduce the likelihood of uninsured vessels causing environmental damage.

However, the use of the IMO as a sanctions-enforcement tool remains controversial. Some Taskforce members emphasised that the IMO is a maritime safety and environmental protection body, not a sanctions-enforcement agency. Others argued that while the IMO should not be co-opted for political objectives, there is scope to use its regulatory mechanisms to address risks that overlap with the shadow fleet’s activities. Empowering the IMO to strengthen transparency requirements for insurance and flag state oversight could directly contribute to enforcement efforts without explicitly linking them to sanctions.

Exploring Hard Security Responses

Beyond legal and institutional frameworks, the Taskforce also explored the potential role of military partnerships in addressing the shadow fleet. The Joint Expeditionary Force (JEF), a UK-led coalition consisting predominantly of Nordic and Baltic states, was identified as a potential enforcement tool. Unlike NATO, which requires consensus for action, the JEF can operate with the agreement of just two member states, making it a more flexible mechanism for targeted interventions. Given that JEF states oversee key Russian oil export routes, including the Arctic, Baltic and Nordic straits, the English Channel and even the Strait of Gibraltar and the Suez Canal (due to the presence of UK overseas bases in Gibraltar and Cyprus), the coalition is well-positioned to monitor and report on shadow fleet activity.

The Taskforce considered how the JEF could be leveraged to enhance maritime domain awareness, which remains suboptimal in many countries that are overly reliant on AIS tracking, which shadow fleet vessels frequently manipulate to evade detection. While military interdiction of vessels remains a highly sensitive issue, the JEF’s role as an intelligence-gathering and monitoring entity could prove valuable. There was discussion about whether the JEF could conduct targeted surveillance operations, tracking sanctioned vessels and sharing intelligence with enforcement authorities. Another proposal involved the possibility of JEF vessels shadowing shadow fleet ships, demonstrating a deterrent presence without direct intervention. However, the legal and political implications of such actions would need to be carefully considered.

The Taskforce concluded that while international legal frameworks such as UNCLOS and the IMO remain foundational to maritime governance, they are not sufficient in isolation to address the complexities of the shadow fleet. A combination of diplomatic engagement, regulatory refinement, enhanced intelligence sharing and military deterrence will be necessary to curtail Russia’s shadow fleet illicit maritime activities. However, any enforcement strategy must carefully navigate the legal and political constraints inherent in the international maritime system to avoid unintended repercussions that could undermine broader maritime trade and security objectives.

Implications of the Trump Administration

As the geopolitical landscape continues to evolve, the Taskforce discussed the potential ramifications of the new US administration for maritime sanctions enforcement. Given the significant role the US plays in global sanctions enforcement, any policy changes under the second Trump presidency could have wide-reaching consequences for the shadow fleet, Russian oil trade, and broader energy markets. Taskforce members also anticipated a greater focus on the Iranian shadow fleet, something all felt should be a focus of a future Taskforce meeting.

While some speculated that a change in leadership might lead to a weakening of sanctions enforcement against Russia, recent indications suggest that President Donald Trump may maintain and even tighten Russian sanctions, at least in the short term, particularly if they align with broader strategic objectives, such as controlling oil prices. Trump has made statements linking oil prices to the longevity of Russia’s war in Ukraine, arguing that lower oil revenues would exert financial pressure on Moscow and potentially shorten the conflict. Unlike previous approaches that primarily targeted individual vessels and owners, some Taskforce members argued that a more assertive enforcement strategy could involve placing pressure on the key infrastructure facilitating sanctioned oil trade, including ports, refineries and intermediaries in third countries. However, it remains unclear whether this strategy would be as effective against Russian oil trade as it has been with Iran, given the complexities of and evasion opportunities presented by the OPC and the diverse range of non-aligned countries willing to continue purchasing Russian crude.

As the US reassesses its foreign policy priorities in the coming months, close monitoring of policy statements and enforcement actions – particularly a greater focus on Iran – will be essential for anticipating the next phase of sanctions strategy.

Recommendations

The Taskforce identified a number of actions to strengthen maritime sanctions and enhance their enforcement:

1. Refine designations: G7+ authorities should continue targeting shadow fleet vessels and key maritime facilitators and related infrastructure. To enhance compliance and enforcement effectiveness, designations should include specific criteria, such as breaching the OPC, ownership links to sanctioned entities, or engagement in deceptive shipping practices.

2. Expedite delisting for compliant vessels: While strict enforcement remains a priority, authorities should facilitate delisting for vessels that demonstrate a commitment to compliance, provided they meet stringent regulatory conditions. Suspicious vessels should remain designated to prevent abuse of the delisting process. Such a system would incentivise behavioural change while mitigating risks of entrenching the shadow fleet’s parallel trade.

3. Grant licenses to safely scrap sanctioned tankers: Designated vessels that are past their operational life expectancy and have deteriorated are at risk of being neglected or abandoned, as they cannot be disposed of in a safe manner due to both a lack of adequate insurance and sanctions-related barriers. The G7+ should explore the introduction of a pooled insurance scheme or licensing regime to enable the navigation of listed vessels to scrappage facilities.

4. Enhance flag state engagement: Diplomatic efforts should frame compliance as an environmental and safety issue to encourage deregistration of sanctioned vessels. As larger registries take steps against the shadow fleet, further engagement with high-risk registries such as those of Gabon and Cameroon should be prioritised to limit their role in facilitating illicit operations.

5. Enhance maritime insurance oversight: Authorities should mandate greater transparency in maritime insurance documentation, ensuring that insurers operating outside the IGP&I adhere to clear financial and compliance standards. The IMO should strengthen guidelines requiring public disclosure of insurance to mitigate environmental risks associated with shadow fleet operations by ensuring that vessels maintain adequate liability coverage.

6. Leverage international frameworks to strengthen sanctions enforcement: Enforcement measures should align with existing international legal frameworks such as UNCLOS, while remaining effective in addressing contemporary security challenges such as hybrid warfare, shadow fleet activities and emerging security threats. While sanctions are not explicitly covered under UNCLOS, broader maritime security and environmental protection provisions can be utilised to enhance regulatory oversight. The IMO should be engaged to improve insurance transparency and flag state due diligence requirements. However, attempts to stretch UNCLOS beyond its intended scope should be approached cautiously, to avoid setting precedents that adversarial states could exploit.

7. Expand regional cooperation and maritime surveillance: The JEF presents an opportunity for coordinated and enhanced targeted monitoring of shadow fleet activities. Expanding and following the example of the JEF’s role in monitoring shadow fleet movements, reporting sanctions violations, and deterring illicit activity through strategic presence could bolster existing enforcement mechanisms.

8. Monitor policy shifts in the US: G7+ partners must monitor policy shifts under the new US administration and ensure alignment in enforcement strategies. While initial indications suggest that Trump may maintain Russian sanctions for now, potential changes in enforcement tactics could have significant implications. An expansion of sanctions activity against Iran and its oil export industry should also be anticipated. Proactive engagement with US policymakers will be essential to maintaining coordination and preventing enforcement gaps that could be exploited by the shadow fleet and its enablers.

The second meeting of the RUSI Maritime Sanctions Taskforce reinforced the importance of adaptive enforcement measures to counter Russia’s evolving circumvention tactics. While progress has been made on designations and flag state engagement, further refinement is needed to ensure sanctions remain effective without creating unintended consequences. Strengthening diplomatic engagement, leveraging international frameworks, and ensuring greater clarity in enforcement actions will be key to maintaining pressure on Russia’s shadow fleet while upholding the integrity of global maritime regulations. The Taskforce will continue to monitor developments – including an anticipated increase in focus from the new US administration on Iranian targets – and provide recommendations to enhance collective efforts in tackling maritime sanctions evasion.

Gonzalo Saiz is a Research Fellow at the Centre for Finance and Security at RUSI, focusing on sanctions and counter-threat finance. His research focuses on sanctions implementation, circumvention and evasion tactics, and sanctions enforcement, primarily through SIFMANet (Sanctions and Illicit Finance Monitoring and Analysis Network). Gonzalo’s research on counter-threat finance includes work on the abuse of non-profit organisations for terrorist financing, crime-enabled terrorist financing, and the financing of right-wing extremism.