Arthur Dedels September 12, 2025September 12, 2025 In recent years, the so-called “dark fleet” has transformed the maritime landscape. This shadow network consists largely of old tankers in sanctioned trades, particularly involving Russian, Iranian, or Venezuelan oil. These vessels often use deceptive practices such as AIS spoofing, ship-to-ship transfers, forged documents, concealed ownership, and rapid flag-hopping. At first glance, the dark fleet may seem remote – a problem confined to operators who flout international rules. In reality, the risks extend beyond those directly engaged in sanctioned trades. Legitimate shipowners and charterers can also find themselves entangled, with consequences ranging from loss of insurance to sanctions exposure. Attraction of the Dark Fleet Sanctions have distorted freight markets. Sanctioned oil must still find a path to market, and demand for shipping capacity willing to carry it has surged. Freight rates for these trades are often double normal levels. For some operators, the temptation to accept a sub-charter or indirect fixture in this “grey” market is strong. Yet what looks like a short-term profit can quickly become a long-term liability. Risks for Charterers For charterers, the obvious risk is being listed under secondary sanctions. The US takes a strict approach: these may apply even if the charterer has no direct link to the US or the sanctioned cargo. Innocent mistakes, such as fixing a vessel later revealed as part of the dark fleet, can trigger enforcement. Deceptive practices add further dangers. Dark fleet vessels often present forged documents. A charterer relying on such documents may inadvertently ship sanctioned cargo. Contractual protections, such as BIMCO sanctions clauses, are useful but not foolproof. These may allow termination if a counterparty becomes sanctioned, but proving breach or managing a mid-voyage issue is rarely straightforward. The result can be costly disputes over deviation, dead freight, or demurrage. Other consequences of sanctions violations include insurance invalidation, cargo claims, fines, refusal to cooperate by banks, ports or third parties, reputational damage, and even criminal charges. Risks for Owners Shipowners are no less exposed. The most immediate threat is the loss of insurance cover. P&I Clubs, sensitive to sanctions compliance, may withdraw cover if a vessel is suspected of prohibited trades. Most ports, financiers and other counterparties will then refuse to cooperate. A single uninsured incident – a collision, pollution event, or cargo claim – can prove catastrophic. Financiers are wary. Owners linked to the dark fleet may find banks unwilling to extend credit, refinance mortgages, or support expansion. Over time, reputational damage can be as crippling as regulatory penalties. Port state authorities are tightening enforcement, with inspections and detentions targeting vessels suspected of sanctions evasion. Owners facing such actions may not only incur fines and delays but also claims from cargo interests when voyages are disrupted. Navigating the Risk Both owners and charterers must treat sanctions compliance as a core priority. Robust due diligence is essential: tracing vessel ownership, monitoring AIS patterns, scrutinising cargo documents, and assessing flag or registry changes. Compliance technology and data tools are indispensable. Clear contractual language is also important. Sanctions clauses must be carefully drafted, not treated as boilerplate. Yet even the best drafting cannot eliminate risk. Ultimately, the safest strategy is a zero-tolerance approach to dark fleet involvement, even if that means forgoing business. The dark fleet is more than a sideshow of rogue operators. It creates traps that can ensnare legitimate players in shipping. For charterers and owners, the greatest danger often lies not in a direct fine, but in cascading consequences: loss of insurance, financing, and reputation. Legal vigilance, rigorous compliance, and commercial discipline are the only safe passage through these uncertain waters.
