Shadow Fleets in the Arctic: Uncharted Waters for Governance and Sanctions

The Arctic is no longer a remote frontier shielded from the geopolitics of oil and sanctions. As Arctic Today recently reported, more than 30 oil tankers linked to Russia’s so-called “shadow fleet” have transited Norwegian waters in 2024 alone, carrying sanctioned crude from Murmansk and other Arctic ports. This activity—designed to circumvent Western sanctions—reveals the fragility of sanctions regimes and the limitations of international ocean governance in addressing coordinated evasion tactics.

While these tankers may technically comply with maritime law, navigating international waters and adhering to basic safety protocols, their operations expose serious enforcement gaps. Flags of convenience, shell ownership, and opaque financing structures shield these vessels from accountability. Their increasing use of Arctic shipping lanes undermines legal norms and environmental protections and calls for urgent international coordination to reinforce a rules-based order in polar waters.

Since Russia’s conflict with Ukraine commenced in 2022, Western allies have imposed sweeping sanctions on Russian energy exports. In response, Russia has assembled a fleet of aging tankers, many uninsured by Western providers and operating under foreign flags, to sustain oil sales to countries like China and India. This fleet is now widely known as the “shadow fleet.”

While these vessels previously navigated through the Atlantic and Indian Oceans, 2024 saw a notable shift northward along the Norwegian coast, with dozens using the Barents and Norwegian Seas as preferred corridors. Their destinations include floating storage units off Kalamata, Greece, and Asian refineries, often after ship-to-ship (STS) transfers in international waters.

Norwegian authorities have voiced serious concerns over the safety and environmental risks of these operations. Many vessels in the shadow fleet are over 20 years old and lack sufficient insurance, raising the risk of spills in the vulnerable Arctic environment which is already under stress from climate change. However, enforcement remains difficult. A large share of these ships sails under flags of convenience such as Liberia, Panama, or the Marshall Islands, which allows them to avoid direct sanctions and inspections. In recent weeks, dozens of Russia-linked tankers have ceased using Liberian and Marshall Islands flags in response to heightened U.S. sanctions enforcement, according to shipping data and industry sources.

This shift into Arctic waters exposes how current ocean governance frameworks fall short in confronting covert or gray-area behavior. The United Nations Convention on the Law of the Sea (UNCLOS) provides a foundation for flag state responsibility and freedom of navigation but offers few tools to address sanctions evasion. Many flag states lack the resources—or the political will—to monitor and enforce compliance. Coastal states like Norway, meanwhile, are restricted by international norms from acting beyond waters under its jurisdiction.

The International Maritime Organization (IMO) sets safety standards and mandates transparency, yet its rules are frequently circumvented through “dark” operations. These include disabling automatic identification systems (AIS), frequent changes in ownership, and falsified documentation. Ship-to-ship transfers in international waters further obscure the origin and destination of cargo, making it much harder to detect illicit activities and trace the supply chain.

Arctic-specific institutions such as the Arctic Council lack enforcement power. Even the IMO’s Polar Code—which aims to improve safety and environmental protection—applies only to certain vessels and does not cover sanctions enforcement or deceptive shipping practices.

Beyond the legal and technical challenges, the shadow fleet’s Arctic expansion raises pressing environmental and strategic concerns. Older tankers often lack double hulls and up-to-date safety systems, elevating the risk of spills in ecologically sensitive zones. Their presence in shrinking ice regions that are increasingly navigable also illustrates how climate change is enabling geopolitical maneuvering.

For NATO and EU member states, the unregulated movement of shadow fleet vessels near critical maritime infrastructure represents a growing security concern. These tankers, often uninsured, aging, and operating under opaque ownership structures, frequently transit through European maritime corridors, including waters near Norway’s offshore energy platforms. Their presence not only increases the risk of environmental disasters—such as oil spills in ecologically sensitive areas—but also raises the threat of sabotage, surveillance, or hybrid interference. As the geopolitical value of energy infrastructure grows, particularly in the context of the Ukraine war and global energy realignments, the shadow fleet’s proximity to these assets highlights an urgent need for enhanced maritime domain awareness, coordinated sanctions enforcement, and strengthened protective measures across European waters.

In response to enforcement efforts targeting the shadow fleet—particularly actions by Estonia and other Baltic states—Russian officials have consistently dismissed such measures as politically motivated and harmful to freedom of navigation. After Estonia detained a Liberia‑flagged tanker in April, Kremlin spokesperson Dmitry Peskov declared that Russia would “defend its ships… with all means available,” framing the incident as hostile Western aggression. Similarly, Foreign Ministry spokeswoman Maria Zakharova criticized Estonia’s new legislation permitting force against certain vessels, calling it a provocative threat to Baltic shipping safety.

This Arctic turn reflects a broader trend: the fragmentation of global ocean governance amid sanctions, shifting alliances, and commercial pragmatism. Countries such as India have increased imports of discounted Russian oil—often transported by vessels associated with the so-called “shadow fleet.” While India is not violating international law by purchasing oil not covered by G7 sanctions, the growing use of opaque shipping networks—including those linked to Arctic-origin cargo—underscores the limitations of current enforcement regimes.

This is not to single out India, but rather to highlight a structural vulnerability: when enforcement mechanisms lack universal participation and legal ambiguities persist, the effectiveness of sanctions is undermined. The issue has become politically charged. U.S. President Donald Trump recently criticized India’s oil trade with Russia, warning of a potential hike in tariffs on Indian imports, citing perceived trade imbalances and strategic misalignment over sanctions.

Meanwhile, China—another key buyer of Russian crude—has recently scaled back its purchases. Its imports of Russian oil from January to June 2025 declined by 10.9% year-on-year, totaling 49.11 million tons. Analysts attribute this dip to the tightening impact of U.S. sanctions on Russia’s maritime exports, as well as China’s efforts to diversify its energy suppliers.  

If the Arctic is to remain a region of peace and sustainability as declared in many national strategies, then ocean governance must evolve to match the complexity of today’s shipping landscape. Coastal states, flag registries, and international institutions must enhance cooperation to track and regulate high-risk vessels. Satellite monitoring, open registries, and real-time data sharing can improve transparency and accountability.

Regional institutions like the Arctic Council, though not enforcement bodies, should integrate maritime monitoring into their agenda and support joint surveillance initiatives.  The EU, Norway, and Canada, each with strong regulatory frameworks, active roles in Arctic affairs, and experience in sanctions enforcement, are well-positioned to lead the development of an Arctic-specific sanctions monitoring mechanism, possibly in collaboration with the IMO and the Financial Action Task Force.

Ocean governance is no longer just a matter of environmental regulation—it is a core arena of geopolitical competition. As global rivalries deepen, sanctions enforcement, maritime transparency, and legal norms at sea are increasingly intertwined. Control over shipping routes, efforts to curb illicit trade, and the defense of a rules-based maritime order are now central to shaping global influence and institutional legitimacy.

The shadow fleet’s Arctic maneuvers are more than a tactic to evade sanctions—they are a wake-up call. While widely viewed as a challenge to international norms, Russia frames these activities as the lawful exercise of maritime trade. This tension highlights the need for ocean governance systems that can respond to covert networks, shifting trade flows, and a transforming Arctic. Strengthening this framework will require smarter tools, stronger coordination, and dialogue that balances sovereign interests with the integrity of international law.