The new sanctions off-ramp: what recent vessel de-listings reveal about shadow fleet enforcement

Vessel-specific sanctions have become one of the core tools used by Western governments to disrupt Russia’s shadow fleet. Since the first wave of Russia-related vessel designations in late 2023, the US, EU, UK and allied jurisdictions have increasingly targeted not only individuals and companies, but individual ships alleged to be transporting Russian oil outside the G7 price-cap framework, helping sanctioned parties move goods, or otherwise enabling sanctions circumvention.

However, the sanctions landscape for Russia-linked vessels has gradually started to change in recent months, following a first wave of vessel delistings by the US, EU, and UK.    While pressure on Russia's shadow fleet continues to increase, regulators appear increasingly willing to remove restrictions where owners can demonstrate changes in ownership, operations or compliance. This marks an important evolution in how vessel sanctions are being used: less as static blacklisting tools and more as adaptable instruments designed to change behaviour. 

Recent delistings 

On 31 March 2026, OFAC made the first significant delisting of vessels, as it removed three Russia-flagged cargo ships - Fesco Moneron, Fesco Magadan and Sv Nikolay - from the SDN List. Soon afterwards, on 8 May 2026, OFAC delisted the Vietnam-flagged tanker Astra, which had been linked to the trade of Russian oil. Most recently, in the designation removals announced on 28 May 2026, OFAC also delisted 14 more vessels which have reportedly been scrapped or decommissioned.

Not long after the US announced its first round of vessel delistings, in its 20th Russia sanctions package, adopted on 23 April 2026, the EU delisted 11 tankers, all of which had previously been linked to the trade of Russian oil. Soon afterwards, the UK suggested it may begin to follow suit - revoking sanctions on Millerovo, a tanker the EU also delisted, on 14 May 2026. 

Meanwhile, the US did not publicise its reasons for delisting the first three vessels in March 2026, but indicated that the delisting was “not indicative of a broader shift in US-Russia policy,” and that the decision came after a “thorough review.” In contrast, the May 2026 delisting of a further 14 vessels was framed as being part of OFAC’s “sanctions modernization initiative.” An accompanying statement from OFAC underlined their aim to ensure the sanctions regime remains targeted, and to show that sanctions are “not intended to be a forever tool,” with removals possible in the case of a change in behaviour or circumstances.

The European Commission described their decision to delist vessels as a demonstration that delisting is possible for vessels “returning to compliance”. Among the 11 vessels delisted were five tankers owned by ASCO, the Azerbaijan state-owned shipping company, who issued a statement citing a “coordinated diplomatic and legal efforts” to have the vessels delisted. 

Further vessel delistings on the horizon 

Sources in our network have indicated that further delistings are being prepared, suggesting that this trend is set to continue. This is reflected in increased activity among legal advisers and sanctions specialists assisting vessel owners and operators with delisting applications and submissions to sanctions authorities, highlighting a growing recognition that vessel sanctions are not necessarily permanent and may be reconsidered where authorities receive additional information regarding a vessel's ownership, operations, cargoes or compliance status.

In some cases, stakeholders have argued that vessels were designated on the basis of incomplete or subsequently outdated information, particularly where later evidence demonstrated that the vessels were engaged in legitimate trade rather than the transport of sanctioned commodities. The recent delistings therefore underscore an important feature of sanctions enforcement: while authorities are willing to impose restrictions where they identify sanctions risks, they also retain mechanisms to review and remove designations when presented with credible evidence that the basis for listing no longer applies or was inaccurately assessed.

What does this mean for the future sanctions landscape 

These developments indicate that sanctions authorities across the US, EU and UK are seeking to create off-ramps for sanctioned vessels. By showing that sanctions regimes are responsive to changes in vessel behaviour and status, all three have shown a willingness to be pragmatic in their approach to vessel sanctions. This has also been demonstrated in relation to the decommissioning of vessels, as both the EU and the US have opened derogation opportunities to facilitate the scrapping of vessels, with the US Treasury Department having recently granted a license to GMS, the world's largest cash buyer of ships for scrap, to purchase four sanctioned vessels for scrapping, in another move that can improve exit routes for owners of sanctioned vessels. 

However, the opening of an off-ramp for sanctioned vessels should not be mistaken for a broad loosening of sanctions policy. Whilst it may be true that the US has not sanctioned any new vessels since January 2025 under the Trump administration, the EU has continued to impose new sanctions. In the same sanctions package that saw the delisting of 11 vessels, the EU added 46 vessels to its shadow fleet list, bringing the total number of EU-listed vessels to 632. These ships are subject to port access bans and restrictions on receiving services. The package also targeted additional vessels, third-country entities, a significant maritime insurer, tanker sales, port infrastructure, LNG services and aims to impose a ban on maritime services connected to Russian crude and petroleum products in coordination with the G7. 

The EU has continued to increase pressure on the operations of shadow fleet vessels in recent weeks, as the European Commission’s proposal for a 21st sanctions package contains an additional 30 vessels to be sanctioned. Meanwhile, on 15 June 2026 the Council of the EU announced EU sanctions on two additional individuals and 24 entities related to the shipment and export of crude oil or petroleum products from Russia.

What are the key risks that remain 

When considering delisted vessels, or indeed any commercial relationship with a delisted entity, gaining a full understanding of their risk profile remains essential. A delisted vessel or entity may still present sanctions, legal, reputational, and operational risk.

Even where a ship is delisted, its owner, operator, manager, or associated corporate group may remain exposed to sanctions. Take, for example, two of the ships delisted by the US: Fesco Moneron and Fesco Magadan. Whilst they may have been delisted, the ships’ reported owner (Russian company Investconsulting LLC) is an affiliate of Far-Eastern Shipping Company (FESCO), which is sanctioned by the EU and the UK. A 92.5% stake in FESCO was transferred to Rosatom, Russia’s state-owned nuclear company, in November 2023 by presidential decree. The ships’ former owner, PJSC Promsvyazbank, has also been sanctioned by the US and EU. 

Another important risk factor is jurisdictional differences. A vessel removed by one authority may remain sanctioned by another. Across the 11 vessels delisted by the EU, a varied patchwork of sanctions remain in place from the UK, Switzerland, Canada, Australia and Ukraine. Sanctions regimes do not always move together, and delisting in one jurisdiction does not neutralise risks in another.

The emergence of vessel delistings demonstrates that sanctions regimes are becoming more nuanced, rather than less restrictive. Authorities continue to expand pressure on Russia's shadow fleet, but they have also signalled that sanctions can be reversed where vessel owners alter their behaviour and circumstances change. For market participants, the challenge is no longer simply identifying sanctioned vessels, but understanding the evolving risk profile of vessels moving between sanctioned and non-sanctioned status.