Russian oil continues to flow to global markets through hundreds of tankers lacking insurance, sailing under third-country flags and officially non-existent in sanctions registries. Kyiv is now promoting a specific mechanism designed to change this situation.
The president's sanctions envoy Vladislav Vasyuk explained Ukraine's approach in negotiations with partners: to fully arrest shadow vessels, it is not enough to simply have a ship on a sanctions list—what is needed is automatic recognition of these lists by the jurisdictions of destination ports.
The problem is technical but critical. Even if a tanker is listed by the US or EU, a port in Turkey, the UAE, or India is not obligated to detain it—because it is not a party to the relevant agreements. The vessel transfers its oil and continues on its way.
According to Vasyuk, Kyiv proposes a two-tier model: the first tier is a coordinated "blacklist" of vessels recognized by multiple jurisdictions simultaneously; the second tier involves obligations for partner ports to detain such vessels without additional national procedures. In effect, this concerns the extraterritorial application of sanctions through bilateral or multilateral agreements.
This is not a new idea in international law—a similar mechanism partially works for vessels flying the flags of states violating weapons embargoes. However, such a comprehensive attempt to apply it to commercial tanker fleets has not been made before.
Skeptics within the EU point out the obvious: Turkey and the UAE, through whose ports the lion's share of shadow traffic flows, are not members of sanctions regimes and have their own economic interests in maintaining these flows. Signing a framework agreement is one thing; implementing real controls is another.
A telling detail: since the beginning of the full-scale invasion, the West has added over 400 shadow fleet vessels to sanctions lists. Documented arrests in neutral ports number only a handful.
If Kyiv's mechanism truly works, it would mean a fundamental shift: sanctions would cease to be a paper threat for countries that officially have not signed them. But that is precisely why the question remains open: which specific countries has Ukraine already convinced to sign agreements on automatic recognition of lists—and by what deadline?
