EU Sanctions Against the Shadow Fleet: When Not Only the Vessel but Also Owners, Operators and Managers Are Listed

EU sanctions against Russia’s so-called shadow fleet are continuing to evolve. While the initial focus was primarily on individual vessels, the EU is increasingly targeting the persons and companies behind those vessels. This may include not only formal shipowners, but also commercial operators, technical managers, ISM managers, insurance brokers, trading structures and other service providers which, in the Council’s view, enable or support the operation of such vessels.

This development is highly relevant for the international shipping sector, shipowners, ship managers, insurers, charterers and trading companies. A listing under Council Regulation (EU) No 269/2014 generally results in an asset freeze. In addition, funds or economic resources must not be made available, directly or indirectly, to listed persons or entities. For affected companies, such a listing may have severe practical consequences, even where the company is established outside the European Union.

From vessel listings to listings of the companies behind them

Since the 14th EU sanctions package against Russia, certain vessels may be listed in Annex XLII to Council Regulation (EU) No 833/2014. Such vessels are subject, in particular, to a prohibition on access to EU ports, anchorage zones and locks. A broad range of services in relation to such vessels is also prohibited, including operation, crewing, chartering, certain financing and insurance services, technical assistance, bunkering, ship supply services and other maritime services.

The measure has been expanded significantly since its introduction. While the EU initially listed 27 vessels, the number has increased substantially over subsequent sanctions packages. According to the Council of the European Union, 632 vessels are now listed following the 20th sanctions package. The vessel list has therefore become a central instrument of the EU’s sanctions policy against the Russian shadow fleet.

The sanctioning was based on the legal basis set out in Article 3s(2)(b) of Regulation (EU) No 833/2014, as amanded:

"Annex XLII shall include vessels that: ... transport crude oil or petroleum products as listed in Annex XXV or mineral products that originate in Russia or are exported from Russia and practice irregular and high-risk shipping practices as set out in the International Maritime Organisation (IMO) General Assembly resolution A.1192(33)."

Legal basis: Regulation 269/2014 and the criterion for owners, operators and supporters

Council Regulation (EU) No 269/2014 is the central EU regime for asset freezes and the prohibition to provide funds and economic resources to listed persons. ompanies listed under this regime face significant economic challenges when selling products or providing services to EU recipients, because the latter are prohibited from paying for those products or services, as such payment would constitute the making available of funds.

The list of listing criteria has been expanded several times. Since Council Regulation (EU) 2025/390 the listing criteria also cover the following ground, which may affect not only the vessel itself but the company as a whole. The wording of Article 3(1)(k) of Regulation (EU) No 269/2014, as amended, is as follows:

"Annex I shall include: ... k) natural or legal persons, entities or bodies that own, control, manage or operate vessels that transport crude oil or petroleum products or mineral products originating in Russia or exported from Russia and practice irregular and high-risk shipping practices as set out in the International Maritime Organisation General Assembly resolution A.1192(33), or that otherwise provide material, technical or financial support to the operations of such vessels; or"

The scope of the criterion is therefore broad. It is not limited to the civil-law owner of a vessel. A commercial operator, technical manager, ship manager, ISM manager, insurance broker or other service provider may also come under scrutiny if the Council considers that it enables, supports or participates in the operation of the relevant vessels.

New listings show the practical relevance

The first listings under this legal basis were made in May 2025 by Council Implementing Regulation (EU) 2025/933. Since then, the list has been expanded continuously. The most recent extension was made by Council Implementing Regulation (EU) 2026/1361. These listings show how the EU is applying this approach in practice. They include numerous shipping companies and shipmanagement companies which, according to the Council’s statements of reasons, acted as commercial operators, technical managers, ship managers or ISM managers of certain vessels.

The statements of reasons often follow a similar pattern. The Council refers to specific vessels, their alleged transport of Russian crude oil or Russian petroleum products and alleged irregular and high-risk shipping practices. Typical allegations include lack of adequate liability insurance, ship-to-ship transfers or manipulation of the Automatic Identification System (AIS). On that basis, the Council concludes that the listed company operates or manages vessels transporting Russian oil or petroleum products while practising irregular and high-risk shipping practices.

For affected companies, one point is particularly important: the published reasons are often concise. They usually contain only a summary of the Council’s assumptions. The underlying file, the specific evidence and the sources relied upon by the Council are often not fully apparent from the published listing text.

Why such listings may be challengeable

Sanctions listings are often based on factual assumptions. In the shipping sector in particular, those assumptions may be incorrect, outdated or incomplete. Ownership databases, AIS data, port-call information, Equasis entries, insurance information, management data and chartering structures are not always current or unambiguous. Moreover, the relevant roles in shipping may differ significantly from a legal and commercial perspective: owner, registered owner, beneficial owner, commercial operator, technical manager, ISM manager, charterer and broker are not the same.

A listing may therefore be challengeable where the Council relied on incorrect ownership or management information, where the relevant vessels did not or no longer transported Russian oil, where alleged high-risk shipping practices are not supported by evidence, or where the role of the listed company has been mischaracterised. A subsequent change in the factual circumstances may also be relevant, for example a change of ownership, a change of technical manager, the termination of certain transport activities or evidence of proper insurance and compliance structures.

What should affected shipowners, operators and managers do?

Affected companies should act quickly. They should identify the relevant legal acts, review the published reasons for listing and check the applicable deadlines. In many cases, the first step should be an information request to the Council of the European Union to obtain further details on the reasons and evidence underlying the listing.

At the same time, the factual basis of the listing should be examined carefully. In shipping cases, this means clarifying the company’s actual role: owner, commercial operator, technical manager, ISM manager, charterer or other service provider. The Council’s allegations should then be tested against documents such as management agreements, ISM records, insurance certificates, class records, AIS data, port documents and cargo records.

A delisting request may be submitted to the Council at any time. If the listing is to be challenged in court, an action for annulment must be brought before the General Court of the European Union within the applicable time limit. A delisting request does not, as a rule, suspend that deadline.

Delisting request and action before the EU General Court

A delisting request and an action before the General Court are separate remedies and may be pursued in parallel. A delisting request can be submitted to the Council at any time, but it does not generally suspend the deadline for bringing an action before the General Court.

A listing should therefore not simply be accepted as final. If the factual basis is incorrect or incomplete, there may be grounds for a delisting request and, where the time limit is still open, for judicial challenge.

Conclusion: the EU is targeting the maritime structure behind the vessels

EU sanctions against the Russian shadow fleet not only concerns individual vessels but also the broader maritime structure behind the transport of Russian oil and petroleum products: owners, operators, technical managers, ISM managers, insurance brokers, payment structures and other supporters.

Kronsteyn assists affected shipowners, operators, managers and other companies in the maritime sector in EU sanctions proceedings, including information requests, delisting requests and actions before the General Court of the European Union.

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Your contact person: Dr. Hendrik Müller-Lankow, EU/German attorney.