There are new warnings over the growing “dark fleet” which is reported to have moved between Euro 4-5 billion in illegal Russian oil exports in the first nine months of this year alone.

The Centre for Research on Energy and Clean Air (CREA) has published a new report on the Russian fleet and called for actions to put an end to its operations.

In a new report it said the lower regulatory standards practiced by flags of convenience states have created an increased risk for environmental safety, seafarer safety, sustainable shipbreaking, and provoked questions on their large-scale effect on maritime cargo transport itself.

“Not coincidentally, a lot of these paradigms also apply to vessels that constitute Russia’s ‘shadow’ fleet, which profit greatly from using open registries to expand their operations and trade,” it warned. “Of the 46 registries that have flagged Russian ‘shadow’ vessels since the full-scale invasion of Ukraine, 23 are classified as ‘flags of convenience’ by the International Transport Workers Federation. Vessels flagged by these 23 registries have helped Russia transport EUR 50 billion of Russian crude oil and oil products since their full-scale invasion of Ukraine — accounting for nearly one fifth of all ‘shadow’ fleet cargo.”

In 2025 though, following the EU, UK and US Office of Foreign Assets Control (OFAC) sanctions on vessels, many open registries have deflagged vessels designated on sanctions lists, and been reluctant to allow new ‘shadow’ vessels to enter their fleet. A reluctance among traditional open registries to offer their services to the ‘shadow’ fleet  has seen the proliferation of many new registries with little to no history on maritime transport.

“While newer flag registries pose a threat towards sanctions enforcement, the more immediate threat is posed by false flagging operations,” CREA added.

Operating while flying a false flag effectively voids these vessels’ insurance and classification and leaves them outside the norms of maritime governance – which comes with increased environmental and security risks when they transit territorial waters.

CREA added in September 2025, 90 vessels operated under false flags – a six-fold increase from December 2024.

“In the first three quarters of 2025, a total of 113 Russian ‘shadow’ vessels have flown a false flag during their operations, transporting thirteen percent of Russian oil – 11 million tonnes, valued at EUR 4.7  billion.,” the report warned. “This practice poses significant security and environmental risks, undermines global maritime rules, and exploits gaps in flag-state governance.”

The report has called for a number of policy changes in an effort to clamp down on the shadow fleet.

These include:

• A unified EU database of legitimate flag registries shared between port authorities.
• Require flag certification for vessels transiting EU waters.
• Expand engagement with and within open registries to tighten net for ‘shadow’ fleet.
• Reform existing flag registration norms.
• EU coastal maritime enforcement authorities, the UK Maritime and Coastguard Agency and the Royal Navy must detain ‘shadow’ fleet vessels operating under false flags.

Gonzalo Saiz Erausquin, research fellow, at the Centre for Finance and Security, Royal United Services Institute (RUSI) added: “CREA’s new data-rich report evidences not only persistent deficiencies in sanctions enforcement but also the deeper structural weaknesses.”