Russian Shadow Fleet
Direct measures against those agencies that supply the shadow fleet with personnel are apparently even more complicated. In principle, the provision of crews for sanctioned ships of the shadow fleet is prohibited in the EU, but enforcement is weak, and the scope of due diligence obligations for non-sanctioned ships is often a gray area, says maritime security expert Gonzalo Saiz of the British think tank Royal Services Institute. "Crewing agencies can always argue that they knew nothing about the ownership of the ship or its ties to Russia."
