Tag Archives: ship-to-ship transfers

Addressing Flag State Abuse in Shipping

There’s a lot more attention being paid to Flag States for shipping, and what kind of job they’re doing to police their members. Much of the attention is due to the abuse of flag state status by companies and owners who want to avoid being caught up in sanctions.

Sanction regimes from major powers, US, UK, EU Paris MOU, and Tokyo MOU, are getting more strict, and exposing companies to much more risk. However, if flag states don’t proactively enforce rules, they could attract ships that do not intend to play by the general international rules.

Some of these rules deal with insurance and protection for cargo owners. Some deal with care of mariners, and some with proper behavior in cargo handling, such as ship-to-ship transfers and carbon emissions in protected international spaces.

Here we highlight an example of lax enforcement turning into stricter rules. In this article, Cameroon, an African nation which operates a ship registry that has grown very fast recently, is going to purge the registry of ships that are sanctioned by the three sanctioning groups. Cameroon has also reportedly stopped new registration of ships known to be sanctioned.

Owners of those ships will need to move them to another registry. There have been frequent accidents involving ships with Cameroon registry; the average age of the fleet registered there is 32.7 years. This is much older than many operators choose to run ships.

Sam Chambers February 13, 2026

https://splash247.com/cameroon-clamps-down-on-shadow-fleet-as-flag-purge-begins/

Shipping rules are principally controlled by the International Maritime Organization (IMO) though other UN agencies play a role. In the next article, the IMO announced a campaign to combat fraud in ship registration. Fraud is a tactic often used by shadow fleet members to get around rules. These ships will claim to be registered in a flag registry when they are not. Sometimes the claimed nation does not even have a registry.

Flagging a ship in a nation’s registry makes shipboard conduct subject to that nation’s laws. Even when a ship is properly registered with a flag, there could be gaps between IMO standards, agreed to by most nations, and national laws. One prominent area is labor rules for mariners, which sometimes are violated by ships’ management.

The IMO can conduct audits of registries’ practice, and the consistency of national and international laws. It’s planning to step up those audits. This will make it harder for shadow shipping to continue practices that do not meet international shipping standards.

Published Feb 12, 2026 11:06 PM by The Maritime Executive

https://maritime-executive.com/article/imo-ramps-up-campaign-to-close-flag-state-enforcement-gap

Update 2/17/2026:

Madagascar, which has no registry, reports multiple ships falsely claiming it as a flag state.

Sam Chambers, February 17, 2026

https://splash247.com/madagascar-exposes-fraudulent-flag-scam/

Dark fleets and Sanctions

We now have two worlds of international commerce, as a result of trade wars and the Ukraine-Russia conflict. As the Western world, principally the EU, UK and related countries and the US look to tighten sanctions on Russian oil exports, some shipowners are finding creative ways to get around the rules set by the West.

One important escape hatch is to flag ships with a Flag State that doesn’t enforce any of the sanctions. While this strategy may not get access to US or EU ports, it allows substandard ships, or those that don’t want to obey rules such as those banning ship-to-ship transfers without proper environmental and safety provisions, to trade with other countries.

Two stories caught my eye this week.

The first article notes that the Cook Islands nation has become a top 30 Flag State, due to the registry of ships that trade Russian, Iranian, or Venezuelan oil, all sanctioned by the Western Powers. Cook Islands is located in Polynesia, and is self-governing, but has an external defense relation with New Zealand. It consists of 15 islands, with a total area of 91 square miles. It has an Exclusive Economic Zone surrounding it, of some 770 thousand square miles. Many of its residents also have New Zealand citizenship. The population is about 15000 as of the 2021 Census. (All figures from Wikipedia, retrieved on July 29, 2024.)

Sam Chambers July 29, 2024

Dark fleet additions see Cook Islands become a top 30 flag

Apparently tankers are the primary ships flagged there; the Russian oil trade needs ships that will carry Russian oil sold at prices exceeding the $60 per barrel cap set by the Western sanctions. Often these are substandard tankers, and since they cannot land at Western ports they may not meet safety, environmental, or ship management standards. A Flag State like Cook Islands will not be in a position to enforce any of the international standards for safe operation.

The article also points out that LNG is also starting to be traded via a shadow gas carrier fleet, largely based in Dubai. Those ships will likely also be registered in Flag States that are unable to enforce international standards.

The second article shows why the shadow fleet is arising. India’s imports of Russian crude oil are skyrocketing to 1.8 million barrels per day compared to just 88,000 bpd in 2022. Part of the reason is logistical constraints, another important part is price. India can buy sanctioned oil at the reduced sanction price from Russia. But they can also buy other Russian oil, possibly at even lower prices, using the shadow trade.

Russian ports are not located where they can conveniently trade with India. But in the dark market, oil can be swapped and traded without incurring sanction restrictions, and more favorable transport obtained. Some movement did occur from the Black Sea through the Suez Canal, but that is now limited because of the Houthi attacks on shipping in the Red Sea. Ships now need to move around the Cape of Good Hope to reach India, adding many miles and days to the voyage. It’s more profitable for a dark fleet tanker, but adds to the full cost of the oil delivered in India.

The article talks about the dangers of using the dark fleet for moving oil. We can expect more oil spills and accidents due to the substandard condition of the ships and the failure of masters to follow international rules.

Seatrade logo

Paul Bartlett | Jul 29, 2024

Indian oil importers’ thirst for Russian crude drives dark fleet demand

Liberia replaces Panama as the world’s largest flag

Flag state selection by shipowners is becoming influenced to a great degree by geopolitical concerns. A sign of this change is Panama’s loss of the largest flag state title.

One of the factors is certainly Panama’s recent attempt to improve the quality of the shipping registered under its flag. The Panama Registry purged a large amount of substandard tonnage from its rolls. Much of this tonnage was ships engaged in dark or gray trade, skirting Ukraine War sanctions on Russia, making unsafe ship-to-ship transfers, and hiding locations from the AIS system.

This action is coupled with Panama’s alliance with the US Coast Guard standards for shipping safety. Ships registered in Panama will need to comply with the rather strict safety rules the US uses. These are signs that Panama wants to be considered a premier place to register a ship with no substandard tonnage.

I believe the shift to Liberia and other flag states is largely determined by geopolitics. The records reviewed here, compiled by Clarksons, show also that smaller states like Malta and Cyprus, which are right in the line of fire of the Ukraine War’s shipping, have also suffered.

It is really interesting that Germany has risen markedly in the rankings. Perhaps this reflects renewed interest in German shipping. Germany has been spending money on shipping recently, deepening the Rhine to reach Hamburg, and also aiding inland water routes to reduce truck traffic and save fuel for the tonnage of cargo moved.

The nice figure below shows the rankings today of the flag states.

 Sam Chambers July 28, 2023

Liberia replaces Panama as the world’s largest flag