Expanded UK Sanctions Heighten Maritime Risk and Compliance Pressure

On Monday, June 21st, the UK added another 135 tankers to its Russia sanctions list, bringing the total number of banned ships over the past 13 months to approximately 424.

Of the newly sanctioned vessels:

• 100% were flagged as high-risk by Windward prior to designation, based on indicators such as dark activity, suspicious cargo movements, port calls in sanctioned regimes, and GNSS manipulation.
  
• 100% had already been sanctioned by other Western authorities.
  
• 30% were flagged under Comoros, the leading registry for sanctioned tankers, followed by Russia at 26%.
  
• 14% were transmitting fraudulent or unknown flags, including Aruba, Benin, Curaçao, Guyana, Malawi, and St. Maarten.
  
• The beneficial owner was unknown in two-thirds of the cases.

Russian exposure is no longer easily identifiable, as sanctions increasingly target entities beyond the vessels themselves.

The UK has now sanctioned two UAE-based firms: Litasco Middle East DMCC — the Dubai trading arm of Russian oil giant Lukoil — and Intershipping Services, which operates the Gabon and Comoros flag registries.

*Lukoil, Russia’s second-largest oil producer and a major exporter, plays a central role in global energy flows. Sanctioning its trading arm will increase scrutiny on any entity moving its crude or refined products; raising compliance pressure on traders, charterers, and shipowners worldwide.

This adds another layer of complexity to maritime compliance, following the EU’s recent move to ban (from January) refined products originating from refineries that process Russian crude.

Europe currently imports around 200,000 barrels per day of middle distillates from India, the world’s second-largest buyer of Russian crude after China, according to Vortexa. This creates an increasingly opaque landscape, where the true origin of cargoes is harder to trace.

For Western shipping companies, maintaining compliance now demands full visibility across the entire supply chain—vessels, cargo origin, and beneficial sellers alike.

Alignment and Divergence: UK, EU, and US Sanctions Strategies 

The close alignment between the UK’s latest sanctions package and the EU’s July 18 measures highlights a growing transatlantic divide — particularly with the United States.

Both the UK and EU agreed to lower the G7 oil price cap to $47.60 per barrel, down from the existing $60, signaling a stricter stance on Russian crude. The US, however, has opted to maintain the higher threshold, widening a rift in enforcement strategy.

Like the UK, the EU has now sanctioned over 400 tankers linked to Russian oil shipments — often for operating as part of the so-called “shadow fleet” through tactics such as dark activity, GNSS manipulation, and fraudulent flagging.

Together, the UK and EU have effectively targeted the bulk of vessels acquired by Russian interests since 2022. Ships that were exclusively deployed to bypass the G7 oil price cap imposed 30 months ago. This move significantly tightens the enforcement net and further complicates compliance for global maritime operators.

The UK government estimates that Russia spent up to $14 billion assembling its shadow fleet. The 135 tankers sanctioned this week alone have transported an estimated $24 billion worth of cargo since January 2024.

As with the EU, the UK is broadening sanctions beyond vessels to include entities and facilitators—intended to heighten the cumulative impact. But so far, designation alone has had limited operational effect on the shadow fleet. These vessels are already excluded from UK and EU ports—places they rarely trade—so the practical disruption has been minimal.

Major buyers of Russian oil, including India and China, as well as several nations in South America and North Africa, continue to accept shipments from UK- and EU-sanctioned tankers. The persistence of this trade underscores the need for broader coordination and more targeted enforcement to curb evasive shipping activity.

Flag Registries in Focus: Navigating Risk Amid Sanctions Escalation

For the first time, the EU and UK have jointly sanctioned a shipping registry operator used to flag Russian-owned or sanctions-evasive vessels. The designation targets Intershipping Services, the private company contracted to run the registries for Gabon and Comoros—two flags frequently used by Russia’s shadow fleet.

According to Windward Maritime AI™, around 10% of vessels flagged under Gabon or Comoros have beneficial ownership or management ties to entities in the UK or EU. Still, a wholesale exit from either flag is not expected. The sanctions apply solely to the current registry operator; if either government terminates the contract and appoints a new provider, the risk profile of newly flagged vessels may shift accordingly.

Neither Gabon nor Comoros has commented publicly on the sanctions. However, flag-hopping is likely to accelerate, as vessels seek out registries not yet under scrutiny. Open registries in Panama, Cameroon, Barbados, and the Cook Islands have policies in place to de-flag ships sanctioned by the EU or UK—posing direct consequences for at least 21 of the 135 newly sanctioned vessels, per Windward AI.

Other affected vessels include 35 flagged in Russia and 18 under registries the IMO has labelled fraudulent.

The effectiveness of this latest UK package remains to be seen, but the message is clear: entities exposed to European and UK markets must now adopt a more rigorous track-and-trace approach—covering cargo origin, vessel flag, and ownership.

*Lukoil, whose UAE-based trading arm was among those sanctioned, exported 14.7 million tonnes of petroleum products and 36.7 million tonnes of crude oil in 2024, according to its May 2025 annual report.