Shadow Fleet refers to tankers and support ships that use deceptive methods to transport sanctioned and hazardous goods. These ships generally try to conceal their source, ownership, and true destination. Despite the fact that this definition is widely accepted in practice, no international convention defines it, and no organization officially maintains a list of these ships.
Challenges of Identifying Shadow Fleet
A ship is recognized as part of the Shadow Fleet due to its operational practices. The composition of ships in this group changes with sales, flag changes, or status determinations, but ships rarely exit this group. When a tanker engages in the trade of sanctioned oil with non-Western insurance and ambiguous ownership, the commercial path back to legitimate trade becomes severely restricted.
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The practical consequence of this situation is non-compliance. Compliance checks are designed to verify identity, meaning that the ship, its flag, the registered owner, and whether any of them are on a sanctions list are examined. Meanwhile, the Shadow Fleet is defined by behavior. A ship can pass all identity checks with a clean result while fully operating within this group.
Diversity of Estimates and Its Impacts
If you ask five organizations how large the Shadow Fleet is, you will receive five different answers, sometimes with a threefold discrepancy. Estimates vary significantly, and older estimates are now considerably outdated. The European Union's External Action Service has reported a range of 600 to 1,400 ships.
These differences relate to scope rather than disagreement. Counts depend on whether support ships are included, whether the measurement includes ships currently carrying sanctioned cargo or all ships in the operational profile, and whether non-sanctioned ships with similar behavior are counted. Figures published over a year ago describe a smaller fleet and a different structure than what exists now.
Interestingly, the fleets associated with Russia and Iran overlap but are not identical, and a count focused on one will overlook ships operating in the other. For a compliance team, the key question is whether this ship is part of the Shadow Fleet, while a more useful question is whether this ship exhibits suspicious behaviors and how much risk it poses.
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