Analysis of sanctioned vessels in the FleetLeaks database reveals clear patterns in how sanctioned operators evade detection—and what compliance teams should watch for.
The Scale of Sanctioned Maritime Activity
As of October 2025, our database tracks 792 sanctioned vessels across multiple jurisdictions. These aren’t just numbers in a spreadsheet—they represent a sophisticated network of maritime sanctions evasion that has exploded in scale since Russia’s 2022 invasion of Ukraine.
The sanctions aren’t scattered randomly. Six major authorities dominate enforcement:
| Authority | Vessels Sanctioned | Coverage |
|---|---|---|
| United Kingdom | 496 | 62.6% |
| United States | 457 | 57.7% |
| European Union | 444 | 56.1% |
| Canada | 310 | 39.1% |
| Australia | 155 | 19.6% |
| New Zealand | 46 | 5.8% |
Note that these percentages exceed 100%—most vessels face sanctions from multiple jurisdictions simultaneously, creating overlapping enforcement that makes evasion more difficult but compliance verification more complex.
Russia’s Dominance: 351 Vessels and Counting
Russia accounts for 351 of the 792 sanctioned vessels—a commanding 44.3% of the total. This isn’t surprising given the scale of sanctions imposed since February 2022, but the number illustrates just how dependent Russia’s sanctions evasion strategy has become on maritime transport.
These 351 Russian-flagged vessels represent what researchers call the “core” of the shadow fleet—vessels that maintain Russian registration despite facing international sanctions. As we documented in our recent analysis of AIS manipulation, many of these vessels employ sophisticated deception techniques including location spoofing, identity theft through sister-ship swaps, and coordinated AIS handshakes.
The Flags of Convenience: Where Shadow Fleets Register
After Russia, the flag state distribution reveals a clear pattern—sanctioned vessels overwhelmingly choose flags of convenience from states with limited enforcement capacity:
| Flag State | Sanctioned Vessels | % of Non-Russian Total |
|---|---|---|
| Gambia | 75 | 17.0% |
| Sierra Leone | 61 | 13.8% |
| Comoros | 45 | 10.2% |
| Oman | 36 | 8.2% |
| Panama | 30 | 6.8% |
| Guinea | 26 | 5.9% |
| Cameroon | 22 | 5.0% |
| Benin | 21 | 4.8% |
These eight flags account for 316 of the 441 non-Russian sanctioned vessels—71.7% of the total.
Why These Flags?
These aren’t random choices. Flag states are legally responsible for ensuring that vessels flying their flags comply with international regulations, including standards for safety, pollution prevention and insurance. Nations like Gambia, Sierra Leone, and Comoros offer several advantages to sanctions evaders:
Limited Enforcement Capacity: Small maritime authorities lack resources to monitor vessels effectively. A report on Russia’s shadow fleet notes that many of these registries have minimal oversight capabilities.
Low Registration Requirements: Quick registration processes with minimal documentation or beneficial ownership disclosure requirements make these flags attractive for shell company operations.
Regulatory Arbitrage: The frequent reflagging of vessels complicates the monitoring of Russian oil shipments. Each flag change requires enforcement agencies to re-establish tracking links, often hindering and delaying monitoring and enforcement processes.
Strategic Positioning: Some flags like Palau (19 vessels) and Vanuatu (12 vessels) are geographically positioned along major shipping routes to Asia, facilitating their use in sanctions evasion schemes.
Oil Tankers: The Primary Target
Vessel type distribution shows an overwhelming focus on oil transport:
| Vessel Type | Count | % of Total |
|---|---|---|
| Oil Tanker | 249 | 31.4% |
| Crude Oil Tanker | 83 | 10.5% |
| Chemical/Products Tanker | 42 | 5.3% |
| Oil Products Tanker | 31 | 3.9% |
| Chemical/Oil Tanker | 20 | 2.5% |
| Products Tanker | 19 | 2.4% |
| Subtotal: Oil-Related | 444 | 56.1% |
| General Cargo | 110 | 13.9% |
| LNG Tanker | 12 | 1.5% |
| LNG Carrier | 9 | 1.1% |
| Other Types | 217 | 27.4% |
More than half of all sanctioned vessels (56.1%) are oil tankers or oil-related vessels. This concentration reflects the economic reality: oil exports remain Russia’s primary revenue source, and maritime transport is the most practical way to move crude oil and refined products to willing buyers in Asia and the Middle East.
The 110 general cargo vessels likely serve a different purpose—transporting dual-use goods, military equipment, or stolen Ukrainian grain, as documented in multiple UN reports.
What This Means for Compliance Teams
1. Flag State Risk Assessment
The data creates a clear risk profile. Vessels registered in the top eight flags of convenience (Gambia, Sierra Leone, Comoros, Oman, Panama, Guinea, Cameroon, Benin) deserve enhanced scrutiny, particularly if they:
- Are oil tankers
- Have recent flag changes
- Operate in routes connecting Russian ports to Asia
- Show patterns of AIS manipulation
2. Multi-Jurisdictional Complexity
With most vessels facing sanctions from multiple authorities, compliance teams need systems that can:
- Cross-reference multiple sanctions lists simultaneously – A vessel might be sanctioned by the UK but not yet by the US, or vice versa
- Track designation dates across jurisdictions – Understanding when each authority sanctioned a vessel helps establish timeline for violations
- Monitor for new additions – With the UK leading at 496 vessels, their sanctions list updates are particularly important to track
3. The Russian Flag Paradox
The 351 Russian-flagged vessels present an interesting compliance challenge. These vessels maintain Russian registration despite sanctions, suggesting either:
- State-backed operations where maintaining Russian flags is strategic
- Trapped vessels unable to reflag due to sanctions
- Deliberate signals to buyers that Russian origin oil is available
Compliance teams should treat any Russian-flagged vessel interaction as high-risk, regardless of current cargo or stated destination.
4. Beyond Oil Tankers
While oil tankers dominate (56%), the presence of 110 general cargo vessels, 12 research vessels, and even 9 yachts suggests sanctions evasion extends beyond energy. Compliance teams should:
- Not assume non-tankers are lower risk
- Understand that general cargo vessels may transport sanctioned goods or dual-use items
- Recognize that “research vessels” may conduct intelligence gathering or cable-cutting operations
Temporal Patterns: The 2022 Inflection Point
While we don‘t have precise designation dates for all 792 vessels in this analysis, research on Russia’s shadow fleet documents that the fleet “has more than tripled in size since sanctions were effected” in 2022.
This matches our database patterns. Of the 351 Russian-flagged vessels, the vast majority were likely designated after February 2022, representing the West’s response to Russia’s invasion of Ukraine. The concentration of flags of convenience vessels suggests many previously “clean” tankers were purchased, reflagged, and pressed into shadow fleet service post-invasion.
The Enforcement Gap
The United Kingdom has sanctioned 496 vessels—39 more than the United States (457) and 52 more than the European Union (444). This isn’t necessarily because the UK is more aggressive; it may reflect:
- Different designation thresholds – What constitutes sanctionable activity varies by jurisdiction
- Intelligence sharing variations – Each authority may have access to different vessel tracking data
- Legal framework differences – UK sanctions law may allow for broader vessel designations
For compliance teams, this creates a challenge: a vessel might be sanctioned by the UK but not the EU, requiring careful jurisdiction-specific screening depending on where your business operates.
Data Limitations and Future Analysis
This analysis represents a snapshot of our database as of October 2025. Several important data points would enhance future analysis:
- Vessel age distribution – Are sanctioned vessels primarily old tankers at end-of-life?
- Ownership networks – How many vessels share beneficial owners?
- Designation timing – Precise dates for when each jurisdiction sanctioned each vessel
- Insurance status – Which vessels maintain legitimate P&I coverage?
- Active vs. inactive – Some sanctioned vessels may be scrapped or inactive
We’re working to incorporate these data points into future reports.
Bottom Line for Compliance
The numbers tell a clear story:
- Russian-linked vessels dominate (44% of all sanctioned vessels)
- Flags of convenience are the norm (71% of non-Russian vessels use eight specific flags)
- Oil transport is the primary concern (56% are oil-related vessels)
- Multi-jurisdictional enforcement is standard (most vessels face sanctions from multiple authorities)
Effective compliance requires:
- Automated screening across all major sanctions lists simultaneously
- Flag-state risk scoring that treats the eight primary flags of convenience as high-risk
- Vessel-type specific procedures with enhanced due diligence for oil tankers
- Regular database updates as new designations occur weekly
The 792 vessels in this database aren’t just statistics—they represent billions of dollars in sanctions evasion, thousands of illicit cargo movements, and a sophisticated challenge to the international rules-based order. Understanding these patterns is the first step toward effective compliance.
Methodology Note: Data extracted from FleetLeaks database on October 14, 2025, covering all published vessel records with active sanctions designations from at least one major authority (US, UK, EU, CA, AU, NZ).