A Popularising Phenomenon: Shadow Fleets

Shadow fleets, also known as ‘dark fleets’ or ‘ghost fleets’, refer to groups of ships that often operate under unclear ownership structures and operate outside international regulations. These fleets are often associated with activities such as sanctions evasion, illicit trade and the pursuit of geopolitical objectives. In recent years, these fleets have attracted more attention due to increased sanctions, heightened geopolitical tensions, and growing demand for covert maritime logistics.

Shadow Fleets as a Popularising Phenomenon

Although it may seem like a mystical concept, the term ‘shadow fleets’ is actually not new. However, the concept of shadow fleets is becoming popular again, especially in relation to the increasingly harsh international sanctions against Russia. 

Thus, the terms ‘shadow fleet’, ‘dark fleet’ and ‘grey fleet’ have come to the fore as the West imposed sanctions on Russia's energy exports and the Kremlin began attempts to circumvent them. However, there is confusion and ambiguity surrounding the concept of shadow fleets. In fact, experts, journalists and politicians often use the terms shadow fleet, dark fleet and grey fleet interchangeably and give general and vague definitions. Accordingly, a situation of confusion and ambiguity becomes inevitable. 

As a matter of fact, this ambiguity and ambiguity makes it difficult to assess the scale of this phenomenon and causes uncertainty or confusion. Therefore, it is necessary to eliminate the conceptual confusion in the first stage. In this direction, the non-binding decision of the International Maritime Organization (IMO) dated 6 December 2023 will be guiding.

In its non-binding resolution dated 6 December 2023, the International Maritime Organization (IMO) agreed for the first time on a precise definition of the term ‘dark fleet’ or ‘shadow fleet’. In this respect, the resolution in question contains the following statements:

‘[The IMO General Assembly] hereby decides that the terms ‘dark fleet’ or ‘shadow fleet’ in the context of this resolution refer to ships engaged in illegal operations for the purpose of circumventing sanctions, avoiding compliance with safety or environmental regulations, avoiding insurance costs, or engaging in other illegal activities. These activities may include

- Carrying out unsafe operations that do not comply with international regulations and strictly defined industry standards and best practices;
- Deliberately avoiding flag State or port State control inspections;
- Failing to maintain adequate liability insurance or other financial assurances;
- Deliberately avoiding commercial dredging or inspections;
- Fail to operate under a transparent corporate governance policy that guarantees the welfare and safety of the ship's crew and the protection of the marine environment; or
- Intentionally switching off the transmissions of devices such as AIS [automatic identification system] or LRIT [long-range identification and tracking system] necessary for ship identification, or concealing the true identity of a ship without a valid safety or security justification.’ 

Although the IMO's definition in question is a guide, it is obvious that it provides an extremely broad framework. Accordingly, there is a need for a narrower definition. Because such a wide scope of the concept makes it difficult to determine certain boundaries in many respects. As a matter of fact, limiting the concept of shadow fleet only to illegal shipping operations leads to a new confusion.

At this point, Windward's proposal of a three-tiered conceptualisation is instructive. Within the scope of Windward's proposal for a three-tier ship identification system, the term ‘cleared fleet’ refers to tankers that do not exhibit any suspicious behaviour and therefore do not fall under the definition of ‘shadow fleet’. Secondly, ‘grey fleet’ is defined as a semi-legal fleet operating in parallel with the cleared fleet and it is stated that this fleet is a completely new phenomenon arising from the ‘Russia-Ukraine War’.

However, Windward explains that the reason why this fleet is called ‘grey’ is that legal status and sanction compliance cannot be clearly determined in many cases due to practices such as the uncertain origins, ownership structures and frequently changing flags of the vessels. Third, the ‘dark fleet’ or ‘shadow fleet’ consists of vessels that resort to deceptive and illegal practices, such as changing identity and location, or deliberately disabling automatic identification systems (AIS).

Russia and Shadow Fleets

The use of the terms shadow fleets or dark fleets is not a new phenomenon. In the past years, such terms have been used for countries such as Iran, North Korea and Venezuela. However, one of the main reasons for the re-popularisation of these concepts is the targeting of Moscow's energy sector with international sanctions following the Russia-Ukraine War. In this context, it is possible to state that the re-popularisation of the concept of shadow fleets is somewhat related to Russia's response to the sanctions against it. This is because it is witnessed that Russia's shadow fleets have been expanding day by day, especially since 2023.

In this process, Russia's fleet expansion takes place in three different ways. The first of these is the transfer of tankers previously owned by Russian organisations to new management companies. In fact, approximately 90 such tankers belonging to the state-controlled Russian company Sovcomflot were transferred to companies in the United Arab Emirates (UAE) and other countries before 5 December 2022. The second is the purchase of vessels over 15 years old from the clean fleet with P&I insurance previously provided by the International Group (IG). 

Currently, about 100 vessels exceeding the ‘insurance age’ limit of 15 years form part of Russia's shadow fleet. The third is the acquisition of very old vessels, aged 20 years or more, from both the shadow and clean fleets. Indeed, more than 200 such tankers would probably have been retired if they had not been repurposed in Russia's shadow fleet. However, the use of older vessels can be a deliberate strategy for shipowners to reduce financial risks and penalties for possible sanctions or regulatory problems. Since these vessels are less valuable, they are easier to dispose of when sanctions are imposed.

At this point, it is claimed that Russia's shadow ship fleet consists of hundreds of ships. However, according to a report by the Kiev School of Economics (KSE) published in October 2024, the volume of Russian oil transported by poorly maintained and underinsured tankers increased from 2.4 million barrels per day in June 2023 to 4.1 million barrels per day in June 2024. Many of these vessels regularly sail in busy European waters, including the Baltic Sea, the Denmark Strait and the Strait of Gibraltar, and according to Bloomberg quoting KSE, 70 per cent of Russia's oil transported by sea in June 2024 was carried by the shadow fleet.

As a result, the rise of shadow fleets poses serious challenges to ensuring transparency, security and fairness in global maritime trade. At a time of intensifying international sanctions and geopolitical tensions, shadow fleets are likely to continue their presence in the maritime sector. Addressing this problem requires global co-operation, technological innovation and increased transparency in ship ownership and operations. Only in this way can the multidimensional risks posed by shadow fleets be mitigated and the sustainability and security of international maritime trade be ensured.