Date of publication: 14 April 2026
Source: Ukrainska Pravda
Until December 2025, Ukrainian sanctions against the “shadow fleet” were aimed at shipowners – legal entities and individuals who are easily hidden behind a chain of offshore companies. Changes to the Law on Sanctions, adopted in July 2025, overturned this logic: now the object of restrictions is the vessel itself.
On December 13, 2025, the President of Ukraine adopted Decree No. 929/2025 on the enactment of the NSDC Decision “On the Application of Personal Special Economic and Other Restrictive Measures (Sanctions).”
The unprecedented sanctions package included 656 “shadow fleet” vessels at once, which are accused of being used by Russia to bypass EU, G7, and other states’ sanctions during the export of oil, petroleum products, and liquefied gas. This is the first, but extremely important step of Ukraine on the path of clearing the sea of gray zones for the aggressor, and here is how it works.
From Subjects to Objects: A Revolution in Approaches
In July 2025, amendments were made to the Law on Sanctions: now restrictions can be applied to sea and aircraft. Since then, the sanctions model in the field of shipping has undergone fundamental changes.
If previously the sanction pressure focused on owners – legal entities or individuals who are easy to hide behind a chain of offshore companies, today sanctions are imposed specifically on the vessel as an object of property rights, which, in general, is uncharacteristic of the legal system of Ukraine.
Now, a change of owner, manager, flag, or port of registry will not help the vessel and its real owners bypass the restrictions, as the sanctions are imposed on the vessel by its unique International Maritime Organization identification number (IMO number), which is indicated in the State Sanctions Register. This means that the restrictions are tied to the vessel and remain in force throughout its “life” or until their official cancellation. The innovations have fundamentally changed the concept of applying sanctions in the field of shipping in Ukraine, making them inevitable.
Content of Restrictions
The sanctions package, calculated for 10 years, forms a regime of total operational isolation, which causes the practical and legal impossibility of making port calls to Ukrainian ports and conducting any economic activity on the territory of Ukraine.
The applied sanctions include:
- restrictions in the form of asset blocking, with a ban on use and disposal;
- complete termination of trade operations and transit through the territory of Ukraine;
- suspension of the performance of economic and financial obligations;
- termination or suspension of necessary licenses and permits;
- prohibition of using the radio frequency spectrum of Ukraine;
- introduction of additional control measures, in particular, sanitary and environmental;
- as well as a complete ban on entering the territorial sea, internal waters, and ports of Ukraine.
Risk Criteria for the Imposition of Sanctions Against the “Shadow Fleet”
The initiator of the introduction of the first sanctions package against the “shadow fleet” was the Security Service of Ukraine – the corresponding submission to the National Security and Defense Council was the result of monitoring and analysis of collected materials.
The Law on Sanctions provides that the factual basis for their application is the establishment of the fact of using vessels in activities that create real and/or potential threats to national interests, national security, sovereignty, and territorial integrity of Ukraine.
The specified criteria are mostly of an evaluative nature, which leaves the subjects of the sanctions initiative and decision-making a certain space for discretion. In practice, vessels that have signs of risk in their biography fall under the “aim” of the authorities:
Circumvention of the “Price Cap”
The participation (including potential) of vessels in russian schemes to bypass Western sanctions during the export of oil, petroleum products, and liquefied gas is a key ground for including a vessel in the sanctions list. The “price cap” mechanism, introduced by EU and G7 countries since December 2022, limits the price of russian oil in maritime transport, and it is the “shadow fleet” that is the main tool for its circumvention.
Vessel Type and Nature of Cargo
We are talking about tankers intended for the transportation of crude oil, petroleum products, or chemical products. It is this category of vessels that is the key link in the mechanisms for bypassing price restrictions on oil and petroleum products, and therefore, they fall under enhanced monitoring.
Ports of Call
A port call to closed Ukrainian ports in temporarily occupied territories is, undoubtedly, a black mark for any vessel. At the same time, a “red flag” is regular port calls of a tanker to russian ports, in particular, Novorossiysk, Taman, Tuapse in the Black Sea, and Ust-Luga, Primorsk in the Baltic. Calls to open ports of the RF are formally not considered a violation (we hope, temporarily), but such vessels inevitably end up on the radars of special services. Subjects of sanctions policy may legitimately suspect such vessels of transporting goods in violation of international sanctions. The logic of special bodies can be reduced to the following: if a vessel (tanker) regularly works in russian ports, it is highly likely integrated into the logistics chains of the “shadow fleet.”
AIS Manipulations
Regular and unjustified deactivations of AIS (Automatic Identification System) without appropriate safety and navigation prerequisites, as well as manipulations with GPS coordinates, are another “red flag” for the tanker fleet. Of course, special attention is paid to the territorial waters near occupied Crimea.
STS (Ship-to-Ship) Transfer
If previously this was a standard logistical procedure, today, in the context of the “shadow fleet” operation, it is regarded as a possible tool for hiding the origin of the cargo, for example, by mixing russian oil with oil of another origin, bypassing the “price cap” by hiding cargo documents. Increased sanctions risk threatens vessels that carry out transshipment with the AIS system turned off or contact sanctioned vessels when conducting STS operations.
Considering the scale of the sanctions package, there is a high probability that this was the result of the work of not only Ukrainian special services, but also successful interaction with Western colleagues. In addition, thanks to digitalization and cooperation with international intelligence/OSINT agencies, the identification of vessels with signs of risk is only a matter of time.
Consequences of Applying Sanctions Regarding Vessels
The main and most obvious consequence of sanctions is the prohibition of sanctioned vessels from entering the territorial sea, internal waters, and ports of Ukraine. In the conditions of martial law, this mechanism has become even tougher thanks to the participation of the military leadership, because any vessel planning a call to a Ukrainian seaport must be included in the daily vessel movement plan. At this stage, Navy units conduct a thorough check of the vessel for its involvement in violations.
If a sanctioned vessel is still able to enter a Ukrainian port, it will be immediately detained (blocked) for the period of the applied sanctions, which for the shipowner will mean the impossibility of leaving the port and total loss of control over the vessel.
In addition, owners of the sanctioned fleet can potentially be accused of financing terrorism (Art. 258-5 of the Criminal Code of Ukraine) or financing actions committed with the aim of violent change or overthrow of the constitutional order or seizure of state power, changing the boundaries of the territory or the state border of Ukraine (Art. 110-2 of the Criminal Code of Ukraine). The basis can be the very fact of regular calls of the vessel to russian ports and payment of port fees and other payments to the budget of the RF, which can be qualified as indirect provision of assets for financing military actions against Ukraine.
Another negative consequence may be the synchronization of sanctions with EU countries, the USA, and other partner states with the aim of introducing similar restrictive measures, which the NSDC instructed directly to the Ministry of Foreign Affairs of Ukraine. Such a mechanism was introduced by the NSDC Decision “On the synchronization of sanctions pressure of Ukraine, the European Union, and other members of the Group of Seven on the russian federation and related entities,” enacted by the President’s decree of June 27, 2025, No. 422/2025. This creates potential cross-border risks, as the synchronization of sanctions regimes can lead to a significant complication or general impossibility of further operation of the vessel in international shipping.
Perspectives of 2026
In 2026, Ukraine continues to strengthen sanctions pressure on the “shadow fleet.” At the beginning of February, the NSDC Decision on sanctions against 10 individuals and 6 legal entities, in particular, companies servicing the russian tanker fleet and transporting oil, was enacted; on February 12, restrictions regarding 91 sea vessels, and on February 21, sanctions against 225 captains of vessels of the Russian “shadow fleet” and entities servicing its activities.
That is, currently the sanctions model demonstrates a comprehensive approach: personal responsibility of those who ensure their operation, from captains to operator companies, is added to the objective responsibility of vessels. The shadow fleet is gradually being deprived not only of freedom of movement but also of personnel and infrastructure support.
Conclusion
The introduction of sanctions against vessels of the “shadow fleet” became a logical response to their subversive activities. Today, “being outside of politics” in the maritime industry is impossible. For shipowners, the “shadow fleet” becomes too expensive and risky an asset, and any contacts with it turn into real risks of receiving a sanctions “black mark.” In modern conditions, compliance is an element of shipping safety on a par with the technical condition of the vessel and the professionalism of the crew, as working with “gray” assets carries the risk of forever losing reputation and remaining outside the legal market. However, the most important remains the precedent: for the first time in the Ukrainian legal system, a sanction is imposed on a thing, and not on a person. The shadow fleet can no longer hide behind an offshore – the vessel is already in the register, and the IMO number cannot be changed.
