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Further 105 Vessels of the So-called ‘Shadow Fleet’ Added to the EU Sanctions List

  • Writer: RA Dr. Hendrik Müller-Lankow, LL.M. (UCL)
    RA Dr. Hendrik Müller-Lankow, LL.M. (UCL)
  • Jul 23
  • 1 min read

Updated: Sep 10


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Under Regulation (EU) 2025/1494, the Council of the EU has added 105 further vessels (oil tankers) of the so-called 'shadow fleet' to the sanctions list in Annex XLII of Regulation (EU) No 833/2014. The listing is in effect since 20 January 2025.


The Council intends to further restrict the activities of vessels that are part of the 'shadow fleet' of oil tankers or that contribute to Russia’s energy revenues. Sanctioned vessels are prohibited from entering the ports and locks of Member States and from receiving a broad range of maritime-related services.


Affected shipowners may successfully challenge the listing of one of their vessels if the conditions for designation under Article 3s(2) of Regulation (EU) No 833/2014 are not met, or if the Council is unable to substantiate their existence.


Shipowners may initially submit a request to the Council for reconsideration and request access to the information on which the Council based its decision. However, communication with the Council and the issuance of a final decision may take three to four months. It is therefore advisable to file an action before the General Court of the EU within the applicable time limit. The deadline for challenging Regulation (EU) 2025/1494 expires on 13 October 2025.



Kronsteyn is a German/European law firm specialised in EU sanctions law. It will provide you with legal support in challenging the listing of your vessel. For further information, please contact Dr Hendrik Müller-Lankow, solicitor.

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