March 2026 — Monthly analysis of Russian fossil fuel exports and sanctions
Authors: Luke Wickenden and Isaac Levi; Data scientist: Panda Rushwood
Russia’s fossil fuel export earnings reach the highest level in two years, with tax revenues from crude projected to double in March.
Key findings
- In March 2026, Russia’s monthly fossil fuel export revenues saw a 52% month-on-month increase to EUR 713 mn per day — the highest in two years — while volumes grew by a more modest 16%.
- Russia’s increase in monthly fossil fuel export earnings was driven by a massive 115% month-on-month rise in seaborne crude export revenues.
- Early estimates, based on a Russian crude price of USD 77 per barrel, indicate a 114% month-on-month increase in Russia’s Mineral Extraction Tax revenues, reaching up to EUR 7.4 bn in March.
- Fourteen shipments of oil products from refineries using Russian crude — and identified as high risk according to EU guidance — unloaded at EU ports in the month of March.
- China’s imports of Russia’s Eastern Siberia-Pacific Ocean (ESPO) grade crude saw a 14% month-on-month rise — the second-highest volume since the full-scale invasion of Ukraine.
- India’s imports of Russian crude oil doubled month-on-month. The biggest shift was in state-owned refineries’ imports from Russia, which saw a massive 148% increase, presumably due to Russian barrels being more available in the spot market, which serve as their primary source of imports.
- In March 2026, almost half (48%) of Russia’s seaborne oil was transported by ‘shadow’ tankers under sanctions. A further 44% of the volume was transported by G7+ tankers. The remainder was transported by non-sanctioned ‘shadow’ tankers.
- In March 2026, 48 ‘shadow’ vessels were operating under false flags at the end of the month.
- The number of vessels operating under the Russian flag has grown sharply since mid-2025, rising from 217 at the start of 2025 to 297 by March 2026 — an increase of 80 vessels (37%).
- Since Ukraine’s drone strikes intensified on 23 March until the end of the month, Russia’s oil loadings at the affected Baltic Sea ports of Ust Luga and Primorsk dropped 53% compared to the same 9-day period in the prior year.
Trends in total export revenue

- In March 2026, Russia’s monthly fossil fuel export revenues increased by 52% month-on-month to EUR 713 mn per day. This corresponded to a less significant 16% month-on-month increase in export volumes in March.
- Russia’s crude oil export revenues rose 94% month-on-month to EUR 431 mn per day. This was largely led by a significant 115% increase in revenues from seaborne crude, which totalled EUR 372 mn per day. The rise in revenues from seaborne crude exports was due to rising prices, while volumes increased 29% month-on-month.
- Pipeline crude export revenues saw a 19% month-on-month increase to EUR 59 mn per day, driven by rising prices.
- Liquefied natural gas (LNG) revenues increased by 5% to EUR 47 mn. The vast majority (65%) of Russia’s LNG cargoes that arrived at their destination in March 2026 were unloaded at EU Member States.
- Pipeline gas export revenues increased by 5% to EUR 57 mn per day.
- Revenues from exports of seaborne oil products saw a 20% month-on-month increase, earning Russia EUR 134 mn per day.
- Coal export revenues grew by 22% month-on-month, reaching EUR 43 mn per day.
| Ukraine’s drone strikes have reduced Russian oil exports at Baltic ports by 53% as of the end of March |
| Since Ukraine’s drone strikes intensified on 23 March until the end of the month, Russia’s oil loadings at the affected Baltic Sea ports of Ust Luga and Primorsk dropped 53% compared to the same 9-day period in the prior year. Russia is heavily reliant on Asian markets to sell its oil — with90% of its total exports of crude delivered to China and India in the first quarter of 2026. At the same time, the majority of its seaborne crude and oil product exports (71% in 2025) depart from the Baltic and Black Sea ports, which host the biggest terminals and refineries. While the Pacific ports are keenly focused towards Asian buyers, their volumes from these buyers remain limited due to capacity constraints. The Baltic Sea terminals are key for Russian exports, with 47% of the total seaborne crude oil and oil product exports (valued at EUR 60.9 bn) departing from them in 2025. Twenty-two percent of their total oil exports departed from the port of Primorsk, and 20% from the port of Ust-Luga. Ukrainian drone strikes on these two ports, first on Primorsk on 23 March, followed by an array of attacks on the Ust Luga terminal on 25 March, have intensified in recent weeks. Satellite imagery showed that many loading berths and fuel terminals were damaged in the strikes. No Russian oil was loaded at any of its main Baltic ports (Ust Luga, Primorsk or St. Petersburg) on the 26th or 27th of March — the first time the ports have not loaded oil for two consecutive days since the start of Russia’s full-scale invasion of Ukraine. The drone strikes also recorded damage at the Kirish refinery, which produces fuels mostly for export, and the installation has suspended operations. From the first strikes to the end of the month, the volume of oil loaded at the three ports of Ust Luga, Novorossiysk, and Primorsk dropped 28% year-on-year. Ust Luga, the worst-affected port, has seen a 74% year-on-year drop in Russian oil exports in the last 9 days of March 2026. Primorsk’s oil loadings also dropped a considerable 32% year-on-year in this same period. |
Who is buying Russia’s fossil fuels?

- Russia’s fossil fuel exports remain highly concentrated, with China dominating purchases of coal and crude oil, Turkiye leading purchases of oil products, and the EU remaining the largest buyer of LNG and pipeline gas — showing Moscow’s dependence on a narrow set of key customers.
- Coal: From 5 December 2022 until the end of March 2026, China purchased 37% of all Russian coal exports. India (19%), Turkiye (15%), South Korea (12%), and Taiwan (4%) round out the top five buyers’ list.
- Crude oil: China has bought 51% of Russia’s crude exports, followed by India (38%), Turkiye (6%), and the EU (1.8%).
- Oil products: Turkiye, the largest buyer, has purchased 26% of Russia’s oil product exports, followed by China (13%), Brazil (11%), and Singapore (8%).
- LNG: The EU remains the largest buyer of Russian LNG, accounting for almost half (49%) of Russia’s total LNG exports, followed by China (23%) and Japan (19%).
- Pipeline gas: The EU is the largest buyer, purchasing 33% of Russia’s pipeline gas exports, followed by China (31%) and Turkiye (29%).

- In March 2026, China remained the largest global buyer of Russian fossil fuels, accounting for 43% (EUR 8.5 bn) of Russia’s export revenues from the top five importers. Crude oil made up 78% (EUR 6.6 bn) of China’s purchases, followed by pipeline gas (EUR 733 mn) and oil products (EUR 562 mn). Coal (EUR 323 mn) and LNG (EUR 245 mn) constituted the remainder of their imports.
- China’s total seaborne crude imports saw a marginal 1% month-on-month decrease in March, while imports from Russia rose sharply by 32%.
- China’s imports of Eastern Siberia-Pacific Ocean (ESPO) grade crude from Russia saw a 14% month-on-month increase — the second highest volumes since the full-scale invasion of Ukraine.
- India was the second-highest buyer of Russian fossil fuels in March 2026, importing a total of EUR 5.8 bn of Russian hydrocarbons. Crude oil products constituted 91% of India’s purchases, totalling EUR 5.3 bn. Coal (EUR 337 mn) and oil products (EUR 178.5 mn) constituted the remainder of their monthly imports.
- While India’s total crude imports recorded a 4% reduction in March, Russian imports doubled. The biggest shift was in state-owned refineries’ imports from Russia, which saw a massive 148% month-on-month increase. Their imports were in fact 72% higher than March 2025, presumably due to Russian barrels being more available in the spot market, which serves as the primary source of imports for them.
- The state-owned New Mangalore and Visakhapatnam refineries had stopped Russian imports at the end of November 2025, but purchases resumed in March 2026.
- Private refineries, meanwhile, registered a more modest 66% month-on-month increase, but remained lower than the same time last year.
- Turkiye was the third-largest importer, purchasing EUR 1.9 bn of Russian hydrocarbons in March. Oil products accounted for the largest share at 44% (EUR 821 mn), followed by crude oil (EUR 517 mn) and pipeline gas (EUR 340 mn). The remainder of Turkiye’s monthly imports from Russia were made up of coal (EUR 188 mn).
- In March, Turkiye’s imports of seaborne crude saw a 22% month-on-month increase, while Russian volumes rose by a more modest 11%.
- The STAR refinery — owned by Azerbaijan’s state energy company, SOCAR — diversified its crude oil imports in March. While the refinery still ran on 67% Russian crude, it also received imports from the Saudi-Kuwaiti Neutral Zone, Iraq, and Libya. Shipments from Iraq to Turkiye departed almost a month before the closure of the Strait of Hormuz.
- The STAR refinery’s total imports almost doubled month-on-month, while Russian volumes rose by a lower 14%.
- The Tupras Aliaga Izmit Refinery predominantly ran on Russian crude in March and marginally increased its imports of Russian crude oil, up 8% month-on-month.
- The EU was the fourth-largest buyer of Russian fossil fuels, accounting for almost 10% (EUR 1.45 bn) of Russia’s export revenues from the top five importers. Sixty-five percent of these imports (EUR 936 mn) consisted of LNG, and another 35% was pipeline gas. The EU’s reliance on Russian LNG rose by 10% month-on-month.
- Brazil was the fifth-largest importer in March, with all of its purchases totalling EUR 501 mn, consisting of oil products.

- In March 2026, the five largest EU importers of Russian fossil fuels paid Russia a combined EUR 1.3 bn. Natural gas — unsanctioned by the EU — accounted for 69% of this.
- Hungary and Bulgaria received EUR 384 mn worth of pipeline gas through the Balkan Stream pipeline.
- Spain was the EU’s largest importer, purchasing EUR 355 mn worth of Russian LNG in March, marking a 124% month-on-month increase.
- All of Spain’s LNG import installations increased imports from Russia in March, with Bilbao receiving the largest quantity. The Sagunto terminal received its first Russian cargo since August 2024.
- Hungary was the second-largest buyer, importing EUR 297 mn of Russian fossil fuels. In March, Hungary’s imports of Russian fossil fuels consisted entirely of pipeline gas. Meanwhile, the Druzhba pipeline, which carries Russian crude oil to Hungary and Slovakia, has remained inactive since 27 January.
- France was the third-biggest importer in the bloc, importing EUR 287 mn of Russian LNG in March. France’s LNG imports from Russia fell 11% month-on-month.
- Belgium was the fourth largest importer, accounting for EUR 219 mn.
- Bulgaria was the fifth-largest importer, receiving EUR 88 mn of Russian fossil fuels, all of which was pipeline gas.

- Despite the EU’s ban on imports of oil products made from Russian crude on 21 January 2026, 14 shipments of oil products from refineries using Russian crude — and identified as high risk according to EU guidance — have unloaded at EU ports in the month of March.
- Nine of these shipments departed from Turkiye’s refineries, four from India and one from Georgia. Some shipments from refineries running on Russian crude unloaded oil products at multiple European ports. France was the largest recipient of shipments from these refineries running on Russian crude, unloading four shipments in March, followed by Cyprus (three shipments).
- In March, Belgium, Bulgaria, Italy, and the Netherlands also received two shipments each from refineries in non-sanctioning countries that partially process Russian crude. Enforcement agencies in Member States must investigate shipments of oil products imported from refineries that run on Russian crude to prevent Russian oil molecules from entering the bloc, which would violate the EU’s recently implemented ban.
- An additional eight shipments from the Hengyi Refinery were unloaded in sanctioning countries in March; seven shipments arrived in Australia, and one arrived in Japan. The Hengyi refinery in Brunei relies predominantly on Russian crude oil.
- Refineries in India, Turkiye, Brunei, and Georgia that use Russian crude exported EUR 830 mn of oil products to sanctioning countries in March 2026. The importers included the EU (EUR 304 mn), Australia (EUR 332 mn), and the US (EUR 168 mn). An estimated EUR 188 mn of these products were refined from Russian crude.
- There was a 23% month-on-month increase in these refineries’ exports to sanctioning countries. While the UK and Canada did not receive any shipments from these refineries in March, the US, EU, and Australia recorded increased oil product imports from refineries processing Russian crude of 60%, 12%, and 22%, respectively.
- The US’s imports came from the Jamnagar refinery in India and the STAR refinery in Turkiye, owned by SOCAR. In March, as much as 39% of the STAR refinery and 25% of Jamnagar refineries’ feedstock came from Russia.
- The Kulevi refinery in Georgia has run solely on Russian crude and has not received a single shipment of non-Russian crude, while also exporting refined products to the EU after the ban came into force. At the end of March, the CEO of its operating company stated that they are working to replace Russian crude oil. Furthermore, the refinery narrowly escaped being added to the EU sanctions list in March.
| Russia’s increased tax revenues in light of the energy crisis |
| The US-Israel strikes on Iran and the subsequent closure of the Strait of Hormuz greatly benefited Russia’s fossil fuel exports throughout the month of March. In addition to allowing Russia to sell oil at sea amid tightening global oil supplies, the situation led to a sharp rise in Urals prices, which almost doubled compared with those recorded between December 2025 and February 2026.
While there has been an increase in Russian export volumes, there has been next to no expansion in the markets themselves. In 2025, 14 countries imported Russian seaborne crude oil — a number that has remained exactly the same in the first quarter of 2026. While some buyers from 2025 have moved away — Myanmar, Indonesia, and Ghana among them — a mere three new countries have been added to Russia’s market. The Philippines and Hong Kong are the only two new buyers that have snapped up Russian crude after the US waiver, while Singapore received a cargo of Russian crude for the first time since the full-scale invasion. The markets for Russian oil products also remain stable with no sharp movements. In the first quarter of 2025, 41 different countries purchased Russian refined products. In 2026, that list expanded by one, to 42. While nine countries that purchased products in Q1 2025 haven’t done so in 2026, there are eleven new additions to the 2026 buyers list. A rise in the price of Russian crude has had a domino effect on Russian revenues from the Mineral Extraction Tax (MET), which accounted for 20% of the federal budget in 2025. MET collections are recorded at the end of the month and calculated based on prevailing prices throughout the month — i.e., taxes for March will be gathered in April and calculated based on prevailing oil prices throughout the month. Early estimates of March tax revenues suggest that, due to a rise in the base price of Russian crude to USD 77 per barrel, there was a 114% month-on-month increase in Russian MET revenues, totalling 700 bn rubles (EUR 7.4 bn at current currency rates). Data suggests that there was a 95% month-on-month increase in MET per tonne (totalling 26,059 rubles) in March, on top of a Unified Tax Payment including final settlements for the last quarter of 2025. Russian MET structure for 2026 remains relatively separated from prices — a departure from the previous year. Despite this, a 5% increase in the price of oil will result in a 6-8% increase in monthly tax revenues. In addition, the Russian budget had accommodated for an annual budget deficit of 1.6% for the year — which was passed according to preliminary figures released by the Government. This increased deficit meant the Government had announced intentions to introduce budget-tightening measures, which have been postponed indefinitely following the spike in oil prices in March. The Russian Ministry of Finance has also announced no intention of allowing any new financial flows to the National Wealth Fund until July, stepping away from regular budgeting rules. |
How are oil prices changing?

- In March 2026, the average price of Russia’s Urals crude rose astronomically, up by 67% to USD 94.5 per barrel, remaining more than double the updated EU and UK price cap of USD 44.1 per barrel, which took effect on 1 February 2026.

- In March, the discount on Urals crude halved month-on-month, averaging USD 6.4 per barrel below Brent.
Sanctioned tankers carry the majority of Russian crude despite G7+ sanctions

- In March 2026, almost half (48%) of Russia’s seaborne oil was transported by ‘shadow’ tankers under sanctions. A further 44% of the volume was transported by G7+ tankers. The remainder was transported by non-sanctioned ‘shadow’ tankers.
- G7+ tankers transported 29% of Russian crude oil exports in March, while non-sanctioned ‘shadow’ tankers accounted for 9% of the total. The largest share, 62%, was carried by sanctioned ‘shadow’ tankers.
- For oil products, Russia’s dependence on G7+ tankers is higher; these tankers transported 69% of Russian oil products in March. Sanctioned ‘shadow’ tankers carried 24% of total Russian oil product volumes, while non-sanctioned ‘shadow’ tankers accounted for 6% of the volume.

- In March 2026, 48 ‘shadow’ vessels were operating under false flags at the end of the month. The vast majority of these vessels appear to be idle, with two switching to the transport of Venezuelan or Iranian oil. Six vessels delivered EUR 480 mn of Russian crude oil and oil products while flying a false flag in March.
- Only three vessels operating under a false flag transited either the Danish Straits, the English Channel, or the Straits of Gibraltar, carrying a combined total of 13,000 tonnes (EUR 16 mn) of Russian crude oil or oil products.
- There has been a noticeable rise in inspection and detainment of Russian ‘shadow’ tankers sailing under a false flag this year. In March alone, four Russian vessels were inspected, boarded, or detained by maritime coastal authorities in Nordic-Baltic 8++ countries in March.
- This included the Ethera, boarded by the Belgian special forces and taken to the port of Zeebrugge; the Deyna, intercepted by the French Navy in the Western Mediterranean; and two ‘shadow’ tankers — the Sea Owl One and the Caffa, detained by Sweden for sailing under false flags. The Caffa — which is a bulk carrier rather than an oil tanker — had been suspected of carrying stolen Ukrainian grain.
- In March, the UK Government also gave permission to the British Military to board ‘shadow’ fleet vessels transiting UK waters. Most importantly, the UK’s announcement mentioned the potential to inspect and detain ‘shadow’ tankers and sanctioned vessels — not just those flying a false flag.
| Sanctioned vessels flock to the Russian flag registry |
| The number of vessels carrying Russian fossil fuels and operating under the Russian flag has grown sharply since mid-2025. This feature has risen from 217 vessels at the start of 2025 to 297 by March 2026 — an increase of 80 vessels (37%). |
| Of the 50 vessels that joined the Russian registry between December 2025 and March 2026, 90% were already sanctioned by the EU, OFAC, or the UK. The growth of the Russian registry reflects the narrowing alternatives for sanctioned ‘shadow’ fleet operators. Many traditional open registries have deflagged large swathes of sanctioned vessels and tightened their registration requirements. For example, Panama’s ‘shadow’ vessel registrations dropped 63% year-on-year in 2025.
Sanctioned vessels that could not secure registration elsewhere have often resorted to false flags, but an increase in enforcement and detentions of falsely flagged vessels has resulted in the Russian flag emerging as an alternative. Currently, European maritime and coastal authorities have detained multiple vessels that sail under a false flag, but none that sail under the Russian flag registry. Almost a third of the 88 vessels that joined the Russian registry since January 2025 — not all of which have remained there — had previously operated under a false flag. |
| Using the Russian registry provides these vessels with a legitimate flag state — albeit one that is itself the target of sanctions, and whose ability or willingness to cover the cost of an accident is questionable. Nevertheless, it extends legal standing that a false flag cannot. It reduces the risk of detention and affords a degree of political protection that vessels operating under false flags do not have.
The shift to the Russian registry has not significantly impacted the vessels’ routes themselves. Twenty of the vessels that joined between December 2025 and the end of March 2026 have already been involved in the transport of an estimated EUR 1.5 bn worth of Russian crude oil. Almost half of this volume was carried on direct port-to-port voyages — primarily from Murmansk — valued at an estimated EUR 742 mn. The largest destinations of these direct trades, in volume terms, were China (30% of total), India (23%), and Syria (17%). A further 31% remains at sea with no confirmed destination. After joining the Russian registry, seven of these vessels transited EU waters via the Danish Straits, the English Channel, or the Straits of Gibraltar, carrying an estimated EUR 385 mn worth of Russian crude oil. The remaining trades involved STS transfers, with Russian-flagged vessels predominantly operating as shuttle vessels on the first leg, i.e. loading crude at a Russian port and transferring it to a different vessel at an STS location, rather than completing the full voyage. From Russia’s Western ports, five vessels shuttled crude from Ust-Luga, Murmansk, and Novorossiysk to STS zones off the coast of Egypt, carrying an estimated EUR 193 mn worth of crude for onward delivery to India and China — all of which will have transited an EU maritime chokepoint. |
‘Shadow’ tankers pose significant risks to ecology and the impact of sanctions

- In March 2026, 400 vessels exported Russian crude oil and oil products. Among them, 250 were G7+ tankers, and the remaining 150 were ‘shadow’ tankers. Additionally, 58 of these ‘shadow’ tankers were at least 20 years old or older — over a third of the ‘shadow’ fleet that delivered shipments in March.
- Older ‘shadow’ tankers transporting Russian oil through EU waters pose environmental and financial risks due to their age, poor maintenance, and inadequate protection and indemnity (P&I) insurance. In the event of an oil spill or accident, coastal states may face significant cleanup costs and damage to their marine ecosystems.
- The cost of cleanup and compensation from an oil spill by tankers with dubious insurance could amount to over EUR 1 bn for taxpayers in coastal countries.

- In March 2026, an estimated EUR 181 mn worth of Russian oil was transferred via ship-to-ship (STS) transfers in EU waters.
- All STS transfers of Russian oil in EU waters were conducted in Spanish (46%), Italian (31%), or Cypriot waters (23%).
- Daily transfers averaged EUR 5.8 mn. G7+ tankers conducted 100% of these transfers.
How can Ukraine’s allies tighten the screws?
Russia’s fossil fuel export revenues have fallen since the sanctions were implemented, subsequently constricting Putin’s ability to fund his full-scale invasion of Ukraine. However, much more should be done to limit Russia’s export earnings and constrain the funding of the Kremlin’s war chest.
Lower the oil price cap to a baseline that tightens Russian revenues
The oil price cap has failed to impose a durable constraint on Russian crude export earnings, working only briefly and selectively for Urals while leaving other grades and export channels largely unaffected. Urals prices have dipped below the USD 60 per barrel cap level (the crude oil price cap level was lower to USD 44.1 per barrel as of 1 February 2026) for mere short periods of time, while ESPO crude has consistently traded well above the cap due to its structural orientation toward China and Pacific markets.
G7+ sanctions have focused on Russian revenues rather than on restricting Russian export volumes — aimed at keeping Russian barrels flowing in global markets and easing fears of supply constraints. Policies such as the price cap are mainly aimed at reducing the price at which Russia could sell their oil.
In January 2026, as Russian oil prices depreciated steeply due to oversupply in the market, the EU proposed a ban on maritime services that facilitate Russia’s crude oil exports. This policy would have, for the first time, targeted Russian oil export volumes and aimed at shrinking the tanker capacity required to transport their oil globally.
A massive spike in oil prices following the closure of the Strait of Hormuz has led to a rethink of this policy to avoid creating further supply crunches in global markets. Therefore, in the face of the current energy crisis of 2026, CREA recommends that the price cap coalition either fix the price cap policy to a base level that severely restricts Russian revenues or implement a value-based sanction, such as a tax on the use of Western maritime services for transporting Russia’s fossil fuels.

- For the price cap policy to achieve its desired impact, strong enforcement is key. In March 2026, full enforcement of the USD 44.1 per barrel price cap would have reduced revenues by 42% (approximately EUR 6.62 bn).
- CREA recommends that the price cap be set to a lowered level of USD 30 per barrel — still well above Russia’s production cost, which averages USD 15 per barrel. This price cap would have slashed Russia’s oil export revenue by 40% (EUR 180 bn) from the start of the EU sanctions in December 2022 until the end of March 2026.
- In March alone, a USD 30 per barrel price cap would have slashed Russian revenues by 43% (EUR 6.72 bn).
- Lowering the price cap would be deflationary, reducing Russia’s oil export prices and inducing more production from Russia to make up for the drop in revenue.
Create better enforcement mechanisms for the price cap policy
- Sanctioning countries must implement measures that address attestation fraud — a key enabler of non-compliance. Maritime insurers or vessel owners currently do not have direct access to the pricing information for the oil they insure or transport, and are reliant on attestation documents provided by oil traders for price cap compliance.
- At the same time, the majority of Russian crude oil is currently being traded by opaque entities located outside price cap coalition countries — such as the United Arab Emirates (UAE) and Hong Kong. These traders can fraudulently underreport the price that they paid to attain Western maritime services for the transport of Russian oil.
- Maritime insurers and oil traders must be required to obtain a bank statement showing that the Russian oil was traded below the price cap to avoid fraudulent attestation documents being produced. This bank statement must be verified by the bank itself to reduce the risk of the oil trader fraudulently producing documents. It would also enable maritime service providers to independently verify the price paid for the oil.
- As an alternative to amending and enforcing the price cap policy, sanctioning jurisdictions could utilise their leverage to tax Russia’s use of G7+ maritime services when transporting its fossil fuels.
Restrict the growth of ‘shadow’ tankers & tighten regulations targeting the refining loophole
- Frequent sanctioning of Russian ‘shadow’ vessels has shifted Russian oil back to tankers owned or insured in G7+ countries. Nonetheless, Russian ‘shadow’ tankers still hold sway on the transport of Russian crude oil. In addition, many sanctioned vessels continue to deliver oil to ports globally, with EU and UK sanctions in particular frequently violated. Sanctioning countries must align their vessel lists and enforcement paradigms for a magnified effect on their operations.
- Maritime coastal states should intensify efforts to monitor, inspect, and detain ‘shadow’ fleet vessels that lack legal passage rights, such as unflagged, unlawfully idle, or security-risk vessels. Authorities must enforce and improve environmental and navigation laws within their territorial waters, investigating and boarding suspicious vessels when justified. Crews involved in criminal activity should face prosecution, and noncompliant ships and personnel should be subject to international arrest warrants.
- In its 18th sanctions package, the EU banned the imports of ‘oil refined from Russian crude’. The regulation bans imports from countries that are ‘net importers’ of crude oil. Net export status does not preclude the import and refining of Russian-origin crude, especially in jurisdictions with flexible or opaque crude sourcing practices. To close this enforcement gap, the exemption should be applied at the refinery level rather than the national level. Refined petroleum products should be subject to import restrictions if produced at facilities that have processed Russian crude within the past six months, regardless of the final product’s declared origin or the host country’s net export position.
- The exemptions for countries including the UK, the US, Canada, Norway, and Switzerland create an opportunity for oil products refined from Russian crude to be re-exported to the EU. This gap should be closed to ensure the sanctions are comprehensive and watertight. The EU should work with its partners to encourage them to also ban the importation of oil products from refineries running on Russian crude.
- Imports of oil products or petrochemicals from storage terminals or re-export hubs in non-sanctioning countries that have received a shipment of Russian oil in the previous six months should be prohibited from exporting to sanctioning jurisdictions. This aims to prevent re-export hubs from obfuscating the origin of imported Russian oil products that are then sent to sanctioning countries, such as the suspicious cases observed in Turkiye and Georgia.
Stronger sanctions enforcement and monitoring of violations
- Despite clear evidence of violations, there is a need for stronger enforcement of penalties by agencies against shippers, insurers, and vessel owners. This information must be shared widely in the public domain. Penalties against violating entities increase the perceived risk of being caught and serve as a deterrent.
- Penalties for violating the price cap must be significantly harsher. Current penalties include a 90-day ban on vessels from securing maritime services after violating the price cap, a relatively minor sanction. If found guilty of violating sanctions, vessels should be fined and banned in perpetuity.
- The G7+ countries should ban STS transfers of Russian oil in G7+ waters. STS transfers undertaken by old ‘shadow’ tankers with questionable maintenance records and insurance pose environmental and financial risks to coastal states and support Russia logistically in exporting high volumes of crude oil. Coastal states should require oil tankers suspected of being ‘shadow’ tankers transporting Russian oil through their territorial waters to provide documentation showing adequate maritime insurance. Upon failing to do so, having been identified as a ‘shadow’ tanker, they should be added to the OFAC, UK, and European sanctions lists. This policy could limit Russia’s ability to transport its oil on ‘shadow’ tankers, which are not required to comply with the oil price cap policy.
- To strengthen the integrity of maritime operations, the International Maritime Organization (IMO) must revise its guidelines to enhance transparency regarding maritime insurance. The IMO should mandate that flag states require shipowners and insurers to publicly disclose key financial information, including insurer solvency data, credit ratings from recognised agencies, and audited financial statements. Maritime authorities of coastal states should be legally able and encouraged to detain tankers that fly false flags and therefore pose environmental and security threats.






