The EU’s 17th Sanctions Package: Targeting Russia’s Shadow Fleet and War Economy

Expanding Sanctions on Russia’s Shadow Fleet

The European Union has introduced its most comprehensive set of sanctions yet in response to Russia’s ongoing aggression against Ukraine. The 17th package specifically targets Russia’s clandestine network of oil tankers, known as the “shadow fleet,” aiming to severely restrict Russia’s oil revenues, a critical source of funding for its military operations.

Central to these new measures is the unprecedented expansion of sanctions on vessels associated with Russia’s shadow fleet. Today’s decision doubles the number of vessels facing EU port bans and prohibitions on critical maritime services, now totaling 342 ships. These vessels, often flagged in third countries, have been identified for their involvement in irregular and high-risk shipping practices designed to bypass earlier sanctions, thus sustaining Russia’s wartime economy.

Targeting the Shadow Fleet Ecosystem

Additionally, the EU is imposing stringent sanctions on entities integral to the shadow fleet ecosystem, including shipping companies and insurers based in the United Arab Emirates, Türkiye, and Hong Kong. This targeted approach aims not only to disrupt immediate logistical operations but also to dismantle the broader networks enabling Russia’s circumvention of sanctions.

Financially, these efforts have already demonstrated significant impact. Since implementing oil price caps and restrictions on the shadow fleet, Russian revenues from oil exports have fallen dramatically—by €38 billion—illustrating the efficacy of coordinated economic measures.

Divergence in U.S.-EU Coordination

Since the start of the war, the U.S. and EU have generally aligned on maritime sanctions and enforcement. However, recent developments suggest this alignment is shifting. In March 2025, the U.S. vetoed a Canadian proposal at the G7 meeting aimed specifically at targeting Russia’s shadow fleet, advocating instead for broader maritime concerns focused on China and reducing explicit references to Russia. Additionally, the dissolution of the U.S. Department of Justice’s Task Force KleptoCapture, a key unit enforcing sanctions against Russian oligarchs, signals further divergence from previously unified enforcement measures.

Windward Analysis: Tracking the Newly Sanctioned Vessels 

Windward’s Maritime AI™ platform offers a uniquely data-driven view of the vessels impacted by the 17th EU sanctions package. While the identities of these vessels were only recently confirmed, our platform surfaces insights based on their historical behavior, ownership structures, and trading patterns—highlighting risk exposure and enforcement trends.
Of the 189 newly sanctioned vessels:

• 97% are tankers
• 99.5% had already been flagged by Windward as high-risk prior to EU designation
• 67% were previously sanctioned, meaning only around 60 vessels are newly designated
• 96% are part of what Windward defines as the gray or dark fleet

This package’s focus on third-country involvement is reflected in the vessels’ registration and ownership. The top flags among the sanctioned fleet are Panama, Russia, Comoros, and Barbados. Meanwhile, beneficial ownership traces largely to Hong Kong, the UAE, China, Seychelles, and Turkey – revealing a deliberate attempt to obfuscate accountability and avoid direct state affiliation.

Windward’s platform also uncovered a high frequency of deceptive and illicit behaviors associated with these vessels over the past year:

• More than 1,000 instances of dark activity 
• Over 790 illicit ship-to-ship (STS) commodity transfers
• At least 30 confirmed GNSS (location) manipulation events

Geographic and Behavioral Trends:

• Commodity STS Transfers clustered around the Mediterranean and Black Seas, with post-meeting destinations commonly including Russia, Egypt, Turkey, and Singapore.
• Dark Activity hubs were located in the Baltic and Black Seas, with follow-up voyages primarily to Russia and India.
• GNSS Manipulation activity was concentrated in the Arabian Gulf and the Malacca Straits.

These patterns indicate that the vessels newly sanctioned by the EU are not merely passive enablers—they are active participants in a systematic campaign to bypass sanctions through concealment, misreporting, and circumvention. Windward’s early detection of 99.5% of these vessels before their formal designation highlights the critical role of proactive maritime intelligence.

UK Sanctions Package: Aligning Patterns Across Borders

Earlier this week, the United Kingdom released a focused sanctions package targeting 18 vessels tied to Russia’s shadow fleet. Windward’s data reveals a strikingly similar profile.

Of these 18 sanctioned vessels:

• 100% were flagged by Windward as high-risk prior to their official designation
• Only 16% had been sanctioned previously, indicating the UK’s proactive targeting of newly emergent threats
• 100% are part of the gray or dark fleet

Top flags among these vessels included Barbados, Panama, and Comoros—further underscoring the reliance on third-country registration for concealment.

Behavioral analysis over the past year revealed:

• Over 170 instances of dark activity
• More than 50 illicit ship-to-ship commodity transfers

This dataset further validates the consistency and predictive power of Windward’s platform in surfacing high-risk maritime behavior before it reaches regulatory thresholds. By identifying and tracking these vessels well ahead of public sanctions designations, Windward provides critical foresight for both commercial and government stakeholders.

Barbados: The New Flag of Convenience

The emergence of Barbados as a popular flag registry in 2024 has raised notable compliance concerns. Windward data shows that prior to November 2023, there was virtually no registration activity under the Barbados flag. That changed dramatically in 2024, with over 190 vessels newly registered under Barbados—67% of which joined in the second half of the year alone.

This rapid rise has coincided with a concerning trend:

• 20% of the vessels switching to the Barbados flag in 2024 were owned by Sovcomflot, all of which previously flew the Gabon flag.
• Today, more than 500 vessels sail under the Barbados flag, yet only 8% have been sanctioned to date—despite significant indicators of risky behavior.

Windward’s platform has flagged a number of behaviors linked to vessels flying the Barbados flag:

• Frequent involvement in dark activities and illicit STS transfers
• Shifting ownership and operational patterns consistent with evasion tactics

This trend underscores the importance of examining emerging registries beyond the surface level. While the Barbados flag may offer operational convenience, it increasingly signals potential risk in the context of global sanctions enforcement.

Standing Watch

As the EU reaffirms its resolve through stringent measures, the message is clear: continued aggression will be met with sustained and intensified economic resistance. As the West escalates its sanctions against Russia, Windward remains vigilant—tracking developments and delivering actionable insights to help stakeholders navigate this evolving landscape. Stay tuned for more updates.

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