--- title: "An Old Clause of the Law of the Sea Wakes Up to Hunt Russia’s Shadow Tankers" description: "Allies used UNCLOS Article 110 to board stateless tankers this year. Then Washington struck a diesel deal with Moscow" author: "Jan Sokol" published: 2026-10-14T14:38:09Z modified: 2026-10-15T04:21:33Z url: https://rews.cc/a/an-old-clause-of-the-law-of-the-sea-wakes-up-to-hunt-russia--5be8dc language: en tags: ["sanctions", "law", "oil", "russia", "ukraine", "world"] publisher: "Rews (https://rews.cc)" --- # An Old Clause of the Law of the Sea Wakes Up to Hunt Russia’s Shadow Tankers *Allies used UNCLOS Article 110 to board stateless tankers this year. Then Washington struck a diesel deal with Moscow* By Jan Sokol · October 14, 2026 · https://rews.cc/a/an-old-clause-of-the-law-of-the-sea-wakes-up-to-hunt-russia--5be8dc ## In brief - Countries sanctioning Russian oil used UNCLOS boarding and inspection rights for the first time this year, experts say - About half of Russia’s crude exports since 2022 have moved on shadow tankers, many sailing under fraudulent or false flags - The US, UK, France and an EU mission have boarded tankers; Denmark has tightened inspections in the Baltic straits - A Russian frigate fired flares at a Danish helicopter on September 14; Danish intelligence warns of growing aggression - Trump announced a deal to buy Russian diesel and lift sanctions on it, drawing criticism from Zelensky and 12 US senators For decades a clause sat in the United Nations Convention on the Law of the Sea, known to lawyers and ignored by navies. Article 110 gives a warship the right to stop and board a vessel on the high seas if it has no nationality. This year, experts told [John T Psaropoulos of Al Jazeera](https://aljazeera.com/news/2026/10/14/law-of-the-sea-comes-to-life-in-the-hunt-for-sanctioned-russian-oil), countries sanctioning Russian oil used those boarding and inspection rights for the first time. “The tool has always been there, but it just never got pulled out of the drawer,” said Kristina Siig, a professor of economic law at Aalborg University in Denmark. ## Ships without a country The sanctions came 45 months ago, from the European Union, the United States and the rest of the G7. They ban buying Russian oil inside the sanctioning countries, and they forbid Western-insured tankers from carrying it to third countries unless it sells below market price. Since 2022 roughly half of Russia’s crude exports have moved on what is called the shadow fleet: tankers with no Western owner or insurer, many of them short of environmental and safety standards. They transfer cargo from ship to ship on the open sea to hide where the oil came from. They switch off their trackers or fake their positions. They skip insurance. They fly false flags. That last habit turned out to be their weak point. Speaking at the 49th Conference on Oceans Law and Policy in Athens, Michelle Bockmann, an analyst at the maritime intelligence firm Windward, said many of these ships sailed under fraudulent registries and were therefore “stateless”. States used to hail such ships and let them go on under innocent passage. Under the convention, she said, they “now had a legal basis to board them.” The aim, in her words, is to “disrupt, deter and make it more expensive and costly for Russia” to move its oil. ![A stylized black and red tanker ship sails on teal water, with a long cream banner flowing from its bow mast and curling behind the stern.](https://rews.cc/img/6393007b1cf7ede4e9e4f731341264d8dde91828.webp) The Western powers had already been working on the flags. They persuaded registries to throw shadow vessels off their books. St Kitts and Nevis went first, in early 2024. Palau, Gabon, Gambia, the Cook Islands, San Marino, Barbados, Comoros, Guinea-Bissau and Sao Tome followed. This year Russia answered by moving many tankers onto its own registry. TankerTrackers.com now counts 340 dark or shadow tankers flying the Russian flag. Here is a small lesson about empires, offered as reflection: when every flag of convenience has been taken away, the ship has to sail under the flag of the state that sent it out. ## The boardings Washington moved first. Late last year, in Operation Southern Spear, it invoked Article 110 against vessels evading US Treasury sanctions on Venezuelan oil. In January US Marines, with British help, seized the Russian-owned *Bella I* in the North Atlantic. It had been sanctioned for carrying Iranian, Venezuelan and Russian oil. Britain and France have since boarded several more ships. Against hundreds of shadow tankers that is very few, but the experts say each boarding adds pressure. On August 2 the Italian navy ship *Thaon di Revel* and a helicopter joined an inspection by the EU mission EUNAVFOR MED IRINI of the EU-sanctioned tanker *Toa Payoh*, west of Pantelleria in international waters. The tanker claimed to fly Cameroon’s flag. The burden falls on the shipping offices as well. “Due diligence has become the biggest headache in ship management,” said George Xiradakis, a maritime consultant who sits on Piraeus shipping boards. He said compliance checks now take several times longer than they did in 2025. ![A cargo ship sails through the center of an open ring binder with blank cream pages, golden rings, and a teal background.](https://rews.cc/img/3c4b75ff8915a3da2271dfce4075f337b7f1dc48.webp) ## The Danish narrows Siig points out that the official reason for all this is safety, a duty every state shares to police the sea. The real purpose, choking Russia’s oil trade because of the war, cannot be enforced under the convention. Only the UN can forbid a state to export, and sanctions need a state’s own jurisdiction behind them. That makes Denmark and Sweden decisive. Tankers loading at Ust-Luga and Primorsk in the Leningrad region have to pass through their narrow Baltic straits, in territorial waters where national law applies. The Danish Maritime Authority recorded 292 shadow tanker transits through the Baltic in 2025. Inspections off Skagen began in February 2025. In April Denmark detained the Vietnamese-flagged *Vigo* over poor fire safety. In October the checks widened to ballast, fuel quality, emissions, waste and certificates. Ships are now asked for oil insurance, a sail plan through the Danish Straits and safety documents. “The Danish approach has been to throw the book at \[Russia\],” Siig said. Moscow has pushed back. On September 14 a Russian frigate fired two flares at a Danish helicopter that was inspecting it in international waters south of Gedser. A report by the Danish Defence Intelligence Service says Russia is acting more and more aggressively toward NATO in the Baltic, that it is under more pressure than at any point in the war, and that its economy is “on the brink of a major crisis.” On October 12, visiting China, Nikolai Patrushev, chairman of Russia’s Maritime Board, claimed that London and Brussels plan “to blockade the Baltic Sea and the straits leading into it.” Siig sees no public evidence of that. The straits are international, governed by transit passage, and Denmark values that system. Her verdict is shorter: “Russia has lost the Baltic.” ![A black bear-shaped chess piece stands on an orange platform between two ivory towers, surrounded by white wave marks against a blue background.](https://rews.cc/img/d47308d96de7bf3735bbc79b948077611acfd082.webp) ## Friday in Washington Then, on Friday, the president who leads the strongest navy among the boarding powers changed course. After a call with Vladimir Putin, Donald Trump said he was lifting sanctions on Russian diesel exports and that Moscow would immediately supply more than 300,000 metric tons, with 500,000 tonnes to follow in November, [according to NPR](https://www.npr.org/2026/10/10/nx-s1-5996938/u-s-and-russia-tout-diesel-deal-to-ease-sanctions-and-reopen-fuel-flows). He named farmers, ranchers and truckers as his priority. Fuel prices are high and the midterm elections are close. Only last month he had signed a sanctions law aimed at Russia’s energy revenues. It gives him until October 18 to impose sweeping new sanctions and tariffs or to waive them in the national interest. Volodymyr Zelensky called it “a weak decision, unfortunately, a weak decision by strong partners.” On Tuesday [twelve senators, six of them Republicans](https://www.cbc.ca/news/world/us-senators-trump-russia-diesel-deal-9.7379187), wrote to ask Trump to rescind the deal and enforce the law. On Monday he had already answered his critics: “I made the right choice for the American People—always America first.” Kyiv wants Russia’s fossil-fuel income gone completely, and warns that Trump’s warming toward Moscow will prolong a war now four and a half years old. It has [struck at least 26 of Russia’s 30 refineries](https://rews.cc/a/zelenskyy-says-ukraine-will-answer-russia-s-new-doctrine-at--c7b8bc) this year. The Centre for Research on Energy and Clean Air calculated that the blockage of the Strait of Hormuz first handed Russia a windfall of €31bn ($35bn) this year. Revenue rose 52 percent month on month in March. Then income from crude, refined products and gas fell: by 1 percent in June, 12 percent in July and 8 percent in August. The boardings, the expelled flags and the Danish paperwork were part of that squeeze. Siig was asked about Ukraine’s demand for still tougher enforcement at sea. It “might stop the Ukrainian war,” she said, “and it might start a new one.”