The European Union is proposing new measures to allow member states to board and inspect ships tied to Russia’s so‑called “shadow fleet,” according to excerpts of a draft EU document published on Oct. 19, 2025. The initiative, prepared by the European External Action Service (EEAS), would lay the groundwork for bilateral agreements with flag states to secure prior permission to conduct vessel inspections and strengthen enforcement against sanctions evasion.
What the draft would do
Under the plan, the EEAS aims to finalise a draft declaration by the end of November and seek approval at the following EU foreign ministers’ meeting. Once adopted, the high representative for foreign affairs would ask the Council for a mandate to open negotiations on bilateral pacts with identified flag states, enabling pre-authorised boardings and targeted measures to disrupt logistics that sustain sanctioned vessels.
Enforcement and tools
The document outlines a mix of measures beyond boardings, including urging flag states to delist sanctioned ships from their registries and proposing further sanctions lists covering tankers, operators, insurers and flag registries. It also contemplates restrictions on material and technical support — explicitly mentioning fuel supplies — to limit the operational capacity of vessels deemed part of the shadow fleet.
Strategic context
The shadow fleet — a network of tankers that frequently reflag, use opaque insurance arrangements and rely on complex intermediaries — is widely viewed in Brussels as a key channel that helps Moscow skirt price caps and sanctions on oil since the February 2022 invasion of Ukraine. Analysts cited in the EEAS material argue that disrupting that network is central to choking a major revenue stream that funds Russia’s military efforts.
Environmental and security risks
EU officials highlight that ships operating with minimal oversight pose environmental hazards and navigational risks: poor maintenance, illicit waste discharge and higher odds of maritime accidents. The draft also flags a potential security dimension, warning that such vessels could be exploited as platforms for hybrid activities, including the launch or support of aerial reconnaissance and attacks targeting critical infrastructure.
State cooperation and precedents
Brussels says it has already engaged with priority flag states and coastal partners that provide logistical services to the shadow fleet, and notes a recent commitment from Panama to delist EU‑sanctioned vessels and to stop registering ships older than 15 years. The draft cites recent operational actions — including national boardings — as signals that member states are increasingly ready to move from declarations to practical enforcement.
Gaps and next steps
The EEAS paper stresses that bilateral agreements with flag states would be a novel instrument in maritime law enforcement for the EU and could set a precedent for strengthening the enforcement chain against reflagging and resale tricks. It also calls for parallel use of targeted individual sanctions on shipowners, captains and crews, and for measures aimed directly at maritime infrastructure such as terminals that enable loading in the Baltic and Black seas.
Implications
If adopted, the package would deepen EU coordination on maritime sanctions enforcement and could raise the political and legal cost for actors enabling the shadow fleet. However, its effectiveness will hinge on the willingness of third‑country registries, insurers and coastal states to cooperate — and on member states’ readiness to translate declarations into sustained operational action.
