SAN002 · Sanctions

Shadow Fleet

Shadow Fleet Operations involve the use of vessels, ownership structures, intermediaries and maritime logistics networks designed to facilitate sanctions evasion, conceal beneficial ownership and transport restricted commodities outside regulatory oversight.

The typology is commonly associated with Russian oil exports, Iranian petroleum shipments, DPRK sanctions evasion and other state-sponsored sanctions circumvention activities.

Unlike traditional sanctions screening risks, Shadow Fleet activity is often identified through network analysis, ownership structures, vessel behaviour patterns and trade route anomalies rather than direct sanctions list matches.

Risk indicators

Ownership

• Common beneficial owners
• Shared directors
• Shared registered addresses
• Offshore holding structures
• Nominee ownership arrangements

Vessel

• Frequent vessel renaming
• Repeated flag changes
• AIS transmission gaps
• Unusual routing patterns
• Ship-to-ship transfers

Jurisdiction

• High-risk ports
• Sanctioned jurisdictions
• Weak regulatory oversight locations
• Free trade zones

Trade

• Restricted commodity movements
• Russian crude oil
• Iranian petroleum products
• Dual-use goods
• Military-related materials

Investigation actions

1. Initial Screening
2. Ownership Analysis
3. Maritime Analysis
4. Trade Analysis
5. Network Review

Detection logic

1. Resolve vessel ownership entities. 2. Resolve vessel management entities. 3. Resolve beneficial ownership structures. 4. Identify links to sanctioned individuals or organisations. 5. Identify ship-to-ship transfer activity. 6. Identify AIS transmission anomalies. 7. Identify high-risk port activity. 8. Assess restricted commodity exposure. 9. Calculate network exposure score. 10. Escalate cases exceeding defined risk thresholds.

Related typologies

Curated from fc-05-sanctions-exposure-analytics-toolkit/typologies/SAN002_Shadow_Fleet.md