Translated material
Approaching a “bright future”: the European coalition and Russia have approached a dangerous threshold in the confrontation over the shadow fleet
Warning shots from small arms from the Russian military frigate "Admiral Grigorovich" towards the peaceful yacht "Bright Future" in the English Channel showed that the European coalition and Russia are very close to the possibility of a military confrontation over Russia's shadow fleet.
The reason for the first phase of escalation was provided by Moscow: Western countries did not actually interfere with the fleet’s activities until the end of 2024, when evidence emerged of its use also for sabotage and reconnaissance purposes in the Baltic. This became the reason for the first detentions of ships.
In 2025, the Western coalition began to increase systematic pressure on the shadow fleet, adding its vessels to sanctions lists and threatening sanctions against countries that provide Russian tankers with a flag and fictitious registration. And in the middle of the same year, a coalition of Northern European countries formulated legal grounds for the detention of ships sailing under foreign flags without real “registration”, in accordance with the UN Convention on the Law of the Sea.
Russia was forced to return some of the ships to the Russian flag in order to provide them with legal status and the possibility of physical protection. Currently, the Russian flag is used by approximately a quarter of ships transporting Russian oil and petroleum products. However, a significant number of tankers still operate under false flags.
Russian authorities are seeking to expand the quasi-legal basis for the protection of such courts by passing a law on the use of armed forces to protect Russian citizens detained by decisions of foreign courts. The law can be used to justify the protection of ships without a Russian flag but with Russian crew members on board. However, such an interpretation is certainly untenable from the point of view of international law and European countries.
Thus, Russia and the European coalition have approached an important point in the confrontation around the shadow fleet. The shots from the frigate Admiral Grigorovich became a symbolic warning in this regard. The answer to the question of whether Europe will retreat after receiving this signal, and whether Russia is ready to use something more than small arms, we will have to find out in the near future.
On June 16, the Russian warship Admiral Grigorovich fired warning shots from small arms in the English Channel towards a yacht that allegedly approached it at a dangerous distance. As it later turned out , the yacht with the ironically sounding name “Bright Future” in this situation and a retired couple on board did not approach the ship (the distance was more than 400 meters) and did not pose a danger, but was, apparently, chosen as an occasion to demonstrate the seriousness of the intentions of the Russian ship, which was already operating in the strait on an almost constant basis. Thus, the episode with “Admiral Grigorovich” marked another step taken on the escalation ladder in the confrontation around the Russian shadow fleet between Moscow and Europe.
Chronicle of the confrontation
It should be noted that in the early stages, responsibility for the escalation of the situation lay on the Russian side. In 2023 and 2024, neither Europe nor the United States tried to prevent the activities of the Russian shadow fleet, although they were fully aware of its scale and role in circumventing sanctions (see the Appendix for the general timeline of the confrontation). Western governments were prompted to take more decisive action at the first stage rather by the fact that the Russian authorities began to use oil-carrying ships also for sabotage and reconnaissance purposes, which created obvious threats to their security, notes, in particular, RAND analyst Henri van Sost .
In 2024–2025, a series of incidents occurred in the Baltic Sea, in which commercial vessels connected to Russia and China were suspected of involvement. The most controversial episode involved the tanker Eagle S, which on December 25, 2024 cut power and several telecommunications cables connecting Finland and Estonia. After this, Finnish special forces boarded the ship and detained the crew. Days later, Finland denied the tanker an operating permit, citing serious safety concerns. And in January 2025, the oil-laden tanker Eventin (which left the Russian port of Ust-Luga under the Panamanian flag) lost control in the Baltic Sea. German authorities towed it to the port to avoid an environmental disaster and announced its confiscation on the grounds of inconsistency of documents (however, legal proceedings on this matter are still dragging on).
Pressure on the shadow fleet began to intensify in the first half of 2025, when the United States and then the EU began to add shadow fleet vessels to their sanctions lists. By July 2025, there were more than 440 vessels in the EU registry, and by October - more than 550 vessels. Meanwhile, Estonia and France detained two more ships in April and October. In the first case, the fact of false registration in Djibouti was discovered, in the second the reason was suspicions of the ship’s involvement in sabotage drone launches, which temporarily paralyzed civil air traffic in Denmark.
As an OCCRP investigation later showed, since mid-2025, individuals with no maritime qualifications associated with the Wagner PMC or the GRU were systematically present on board the Baltic tankers of the Russian shadow fleet. In addition to security tasks in the event of the seizure of ships, they were engaged in electronic reconnaissance, monitoring the movements of NATO forces, and could also coordinate actions with ships of the Russian Navy. The presence of military-related persons without maritime qualifications gave the European authorities legal grounds for detention: the militarization of the crew deprives the ship of the status of an ordinary commercial vessel, and it loses the right to innocent passage under the United Nations Convention on the Law of the Sea (UNCLOS).
However, the main legal justification for actions against Russian ships was developed in June 2025 within the framework of a coalition of 14 countries of the Baltic and North Seas. The coalition declared its readiness to strengthen counteraction to the shadow fleet in its waters , in particular with regard to ships flying false flags, that is, those that do not have actual registration and therefore are not subject to the Convention. The European authorities are appealing to Article 110 of UNCLOS, which provides for the possibility of such actions in relation to such vessels. In parallel, in the second half of 2025, the EU leadership “did a lot of work” with “flag countries” - jurisdictions that provide fictitious registrations to vessels of the shadow fleet - as part of the preparation of the 19th package of sanctions, Bloomberg reported, citing an internal document of the European Commission . They were forced to remove ships associated with the shadow fleet and those on the sanctions list from their registries.
In December 2025 - January 2026, the escalation on the water received a powerful impetus from the United States, which began a strict naval blockade of Venezuela, detaining or stopping, among other things, seven tankers somehow connected with Russia. This operation and Russia’s very restrained reaction to it (which at that moment was counting on Trump’s support in putting pressure on Ukraine and therefore did not want to quarrel with him) to a certain extent normalized the practice of detentions.
In the first half of March 2026, first France and Belgium, and then twice Sweden, detained three ships at once (Ethera, bulk carrier Caffa and Sea Owl I) on charges of lack of registration: the ships were not listed in the registers of the countries whose flags they flew. EU Foreign Policy Emissary Kaja Kallas thanked the countries that carried out the detention and called for consistent action in the same direction. And on March 25, the British Prime Minister gave the kingdom's military forces the right to detain and inspect ships of the shadow fleet. The 20th package of EU sanctions against Russia, published on April 23, expanded the powers regarding actions against Russian tankers. Finally, in pursuance of these measures, in early June, at a meeting of EU defense ministers in Nicosia, the mandate of the IRINI mission, created to monitor sanctions against Libya in the Mediterranean world, was expanded - now its powers began to include monitoring sanctions measures against Russia, and the procedure for detaining and inspecting tankers associated with Russia was agreed upon.
However, in total, during the period from March 20 to June 15, five ships were detained in European waters. The most spectacular of these actions was the landing of British marines on the Smyrtos tanker on June 14. In total, since December 2024, 22 vessels related to the Russian shadow fleet have been detained. Of these, nine arrests were made by European countries in 2026. Thus, detentions, in fact, remain isolated, despite the fact that hundreds of ships carrying Russian oil pass through the same routes every month. (So, according to CREA estimates , in May 2026, a total of 337 vessels were involved in the maritime transport of oil and petroleum products, of which the shadow fleet accounted for slightly less than half - 147.) At the same time, as before, the main legal basis for detentions in international waters is the lack of actual registration of the vessel in the country under whose flag it flies.
Double Russian response
Back on February 17, 2026, shortly after the French Navy boarded the tanker MV Grinch, former Secretary of the Russian Security Council, and now Presidential Assistant for Shipbuilding and head of the newly established Maritime Collegium Nikolai Patrushev said that Russia considers the practice of such detentions illegal, considers it as piracy and can use naval forces to counter it.
However, in reality, the Russian shadow fleet is faced with a real legal conflict. Under pressure from the EU, the ships' home countries began to remove sanctioned tankers from their registries, which created legal grounds for their detention. As a result, the Russian authorities were forced to return the ships to the Russian flag. According to a review by the Kiev School of Economics (KSE) , at the beginning of 2022 there were 75 Russian-flagged tankers, and as the shadow fleet increased, their number dropped to 48 by the fourth quarter of 2024. However, their share of the total number of ships carrying Russian energy resources fluctuated in the range of 7–12%. However, already in 2025, the number of tankers with the tricolor increased to 77, with two-thirds of transitions under the Russian flag occurring in the fourth quarter (18 tankers). In the first quarter of 2026, five more were added (the total number increased to 82). (According to slightly different data from S&P Global Market Intelligence, in the fourth quarter of last year alone, 25 tankers changed their flag to Russian, of which 18 in December, The Wall Street Journal reported ). As a result, the share of Russian-flagged tankers in the total fleet used for maritime transportation of Russian oil and petroleum products increased to 12%, and in the shadow fleet to 24%. From January to March 2026, tricolor tankers delivered, according to KSE estimates, 56.5 million barrels of oil cargo, which is 3.5 times more than in the same period last year.
Graph 1. Share of tankers flying the Russian flag in the total volume of exports of Russian oil and petroleum products, 2022–2026
Perhaps the most scandalous example of an emergency flag change was the case of the Bella-1 tanker, which in December 2025 was pursued by US ships for participating in the transportation of sanctioned oil from Venezuela and Iran . During this chase , the crew painted the tricolor on board , and Moscow retroactively approved the vessel's registration without inspecting it. This is a violation of Article 92 of UNCLOS, which prohibits changing the flag without an actual transfer of ownership, noted Jose Macias of the Center for Strategic and International Studies (CSIS ).
One way or another, the transition of ships under the Russian flag is designed to have a dual effect: they should increase the risks of countries detaining tankers (the first experience of military escalation around the arrest of a vessel took place back in May 2025, when Estonia tried to stop the Jaguar tanker in the Gulf of Finland : after the Su-35 fighter approached the scene of the incident, the interception attempt was stopped), and at the same time deprive such actions of legal grounds from the point of view of international law. Since European, British and American sanctions against Russia have not been approved by the UN, the detention of ships on their basis is a violation of UNCLOS. At the same time, the transition to the Russian flag complicates shipping: the EU is increasing pressure on organizations and ports that provide assistance to tankers under sanctions. On June 15, the EU Council imposed sanctions against 24 legal entities and two individuals involved in organizing the activities of the shadow fleet. Even more large-scale sanctions against ports and port infrastructure of third countries involved in supporting the Russian shadow fleet are expected to be included in the 21st EU sanctions package . These measures, however, will only apply to assisting vessels that are on EU sanctions lists.
This legal conflict is well illustrated by previous episodes of Russian ships passing the English Channel under the protection of the Admiral Grigorovich (according to the British military , the ship has been plying in the strait area for a long time and has recently carried a Russian submarine and at least six tankers of the shadow fleet through it). According to London's The Telegraph , on April 8, shortly after Keir Starmer's permission to detain Russian ships, the frigate was escorting two tankers into the English Channel: Universal, which sailed under the Russian flag, and Enigma, which sailed under the (most likely false) flag of Cameroon. Moreover, both ships are on the British sanctions lists. Formally, the warship accompanied the first (Russian) ship, and such an action is legal from the point of view of international law. However, at the same time, the second tanker also found itself under the protection of the Admiral Grigorovich. It is interesting that the ship under the Russian flag left the port of Vysotsk on January 18, and the second one left the port of Primorsk on March 29. That is, the first ship, apparently, was waiting for the second one in order to cross the English Channel with it under the protection of a warship.
However, the Russian authorities are seeking to expand the quasi-legal grounds for protecting ships without a Russian flag. Back on March 18, 2026, immediately after three Russian tankers were detained in European waters, a bill on extraterritorial protection—the use of armed forces abroad to protect Russian citizens—was introduced into the Duma. The law, which Russian officials sometimes describe as being similar to the US Military Protection Act (ASPA, 2022), is actually broader and essentially unprecedented. Unlike the American law, which deals with the non-recognition of international bodies of justice, the Russian law deals with the non-recognition of “decisions of courts of foreign states vested with powers in the field of criminal proceedings by other foreign states without the participation of the Russian Federation.” In other words, the reason for applying the law may be a decision of a court of foreign jurisdiction to detain a Russian citizen. Including the detention of shadow fleet vessels even when they do not sail under the Russian flag, but their crew includes Russian citizens. The law was adopted and signed by Putin on May 25, and the date of its entry into force is June 5 .
The seizure of the tanker Smyrtos by British marines occurred later than this date, but the ship was under the flag of Cameroon, and there were no Russian citizens among its crew members, which was promptly confirmed by the Russian embassy in London . However, as we see, the Russian authorities gave an “asymmetrical response” to it, firing warning shots towards unsuspecting British pensioners. However, a truly acute conflict will arise if the April situation with two tankers under the protection of a Russian frigate is repeated: from the point of view of the British legal regime, the kingdom’s military forces can detain a tanker that is not sailing under the Russian flag; at the same time, from the point of view of the updated Russian legislation, a Russian warship will have the right to protect it if there are Russian citizens on its crew.
Thus, Russia and the European coalition have approached an important point in the confrontation around the shadow fleet. The position of European countries is that ships without registration cannot enjoy the right of free passage and may be detained, while Russia has stated that it does not recognize the decisions of European courts and intends to counter them with military force. We will have to follow the further development of this conflict and find out the answer to the question whether Europe will retreat before the symbolic shooting of “Admiral Grigorovich” and whether Russia is ready to use something more than small arms.