August 8, 2026: Two months ago, the Russian oil tanker Deliver was seized in the Mediterranean by a French warship. The Deliver was using falsified or meaningless documents and, like so many other Shadow Fleet tankers, was either underinsured or uninsured and operating under a false flag. Delivery purported to be registered in Cameroon, but wasn't. Any of those failings is illegal under maritime law and entitles any nation to seize a ship. This power was used only rarely until the US captured Venezuelan dictator Maduro and asserted these powers. In the past few months, other nations, such as Britain, France, and Germany, have also begun to do so.

Earlier this year, Germany began seizing illegal Russian Shadow Fleet tankers that move sanctioned Russian oil to customers worldwide. This Shadow Fleet consists of about five hundred ships, many of them barely seaworthy and lacking insurance. Since 2022, when Russia invaded Ukraine and was hit with the first of several rounds of economic sanctions, the Shadow Fleet began with about a hundred ships and grew each year. Oil is Russia’s principal export and the source of the money needed to maintain its forces in Ukraine. Germany is one of the 32 NATO nations enforcing the sanctions, which has led to the current crackdown on Shadow Fleet ships in the Baltic Sea. This body of water can only be entered via the Danish Straits. At the other end of the Baltic is the Russian port of St Petersburg. If the German crackdown continues and intensifies, the Baltic will no longer be available to the Shadow Fleet.

Russia’s economy and war effort against Ukraine are financed by oil and other energy exports. Russia is operating under severe economic sanctions imposed to reduce that income and create economic conditions for Russia that make it difficult to impossible to continue its war in Ukraine.

The key to Russian oil exports is the use of foreign tankers to smuggle its petroleum and coal from Russia to overseas customers. 80 percent of China's oil is transported by pipeline and cannot be disrupted. China accounts for nearly half of Russian petroleum and other energy exports. It’s the other half that is at risk because of a growing list of sanctions.

The economic sanctions were imposed on Russia because of its 2022 invasion of Ukraine, in an effort to reduce its hard currency income from exports of oil and natural gas. These are the main Russian exports and the major source of income for the Russian government and war effort. To evade these sanctions, Russia created a growing shadow fleet of oil tankers purchased and/or leased abroad and obtained unrestricted access to a Chinese smuggler haven maintained in Hong Kong.

Current estimates are that over 500 tankers are smuggling sanctioned Russian petroleum to customers in China, India, the European Union/EU, Turkey and Myanmar. Most refined petroleum products go to Turkey, China, Brazil, Singapore and India. The rest goes to nine countries in the Middle East, Africa and Taiwan. China has been buying 47 percent of the crude oil, while India takes 37 percent, followed by Turkey and the EU with six percent each. China, India and Turkey account for about 90 percent of Russian income from the sale of oil, natural gas and coal. The U.S. is imposing additional tariffs on countries that import Russian oil. India is already subject to these tariffs, which increase what it has to pay for imports from the United States. The Americans are negotiating with China and Turkey over what tariffs are being imposed to discourage Russian oil imports.

The nations enforcing the sanctions, particularly the United States, have tracked the routes of the Russian shadow fleet and noted Hong Kong's key role in arranging the movement of sanctioned Russian oil to its primary customers in China and India. Hong Kong is also a major source of weapons and munitions for sanctioned nations. A current customer is Russia. Hong Kong does this by allowing Russian tankers and cargo ships, operating under false credentials to conceal their Russian affiliation, to bring in Russian oil and other raw materials. The Russian ships then leave Hong Kong carrying weapons for their war in Ukraine.

Another major player in the Russian smuggling effort is North Korea. For years, North Korea has been buying small, second-hand cargo and tanker ships and using them for smuggling. A favored evasion technique is to take on or transfer cargo at sea within its own territorial waters. The North Korean merchant fleet consists of about 150 ships, mostly purchased from Chinese firms.

North Korea is a notorious and persistent maritime smuggler. Because of North Korean smuggling, the United States expanded its maritime smuggling and sanctions enforcement program in 2018 when a new multi-national enforcement organization was created. Initial members were the United States, Australia, Canada, New Zealand, Britain, France, South Korea, and Japan. The Enforcement Coordination Cell, or ECC, is enforcing the UN sanctions that curb North Korean smuggling related to items needed for their nuclear and ballistic missile programs. In addition, the ECC allowed member nations to enforce other sanctions or naval missions that their governments prioritized. The U.S. has since invited India, Vietnam, Indonesia, and the Philippines to join and assist with monitoring growing Chinese violations of offshore water rights, especially in the South China Sea and other areas of the West Pacific.

The ECC focuses on the 2,000-kilometer-long shipping lane from the Indian Ocean, through the Strait of Malacca and the South China Sea, to North Korea. Along this route, not only North Korean-flagged ships participate in smuggling, but also Chinese, Taiwanese, Liberian, and Sri Lankan ships, as well as independent vessels that fly whatever flag they believe will keep them from being seized for smuggling. Earlier U.S. efforts had already identified many North Korean and Iranian-owned tankers and cargo ships that were often engaged in smuggling. This led Iran and North Korea to use their own ships less and willing foreign ships instead. These third-party ships are the ones the ECC sought to identify. These ships can be identified, along with their owners, and the owners can have banking and other sanctions placed on them. Many nations not part of the ECC but economic partners of ECC members will cooperate if a smuggler ship visits one of their ports. At that point, the captain can be arrested and the ships detained.

The ECC member warships do not depend on inspecting suspicious ships while at sea but on confirming who is where and when. This is especially useful for spotting smugglers who often turn off their location beacons and continue in running dark mode. These location beacons transmit their current ID and location to any nearby ships and, often via satellite, to their owner and international shipping organizations. The location data, past and current, can be found on several public websites. The beacons exist mainly as a safety measure for ships operating at night or in bad weather in heavily used shipping lanes. Smugglers have learned to turn off their beacons near a port where they are assumed to have docked or anchored offshore, waiting for a dock to become available.

Some smugglers are using spoofing, a form of jamming that just modifies the beacon signal to present a false location. This is where warships and maritime aircraft come in: they can identify ships visually or by radar, followed by visual inspection. This is more damaging to the smugglers because it provides more evidence that their ship was involved in smuggling. With enough evidence, you can go after the ship owners and seize the ship whenever it enters coastal waters within 22 kilometers of land belonging to a nation that will seize outlaw ships. The United States has also seized such ships in the open sea, a practice that governments can and have undertaken under international law.