Rebuilding Leverage
EU maritime Sanctions on Russian oil after four years
By the late spring of 2026, Ukrainian drones had caused significant damage to Russian refining capacity; unable to process as much crude domestically, Russia diverted more of it to foreign markets, leading to the highest level of seaborne crude exports since the start of the full-scale invasion of Ukraine in 2022.
The network of tankers with opaque ownership that Moscow has assembled during the last four years (commonly known as Russia’s shadow fleet) lacked the capacity to carry the new export volumes. Therefore, crude exports shifted onto the tankers that conventionally carried Russian crude before the war, insured by the International Group of P&I clubs, and fell under the price-cap sanction regime. Between April and July, the share of Russian crude carried by tankers owned or insured in G7+ countries rose from 23% to 34%; yet, Urals Oil crude traded well above the $44.10 per barrel (bbl, ~159L) EU price cap, indicating that large volumes of Russian crude continue to be exported beyond the reach of the sanctions regime’s enforcement.
Some could see the evasion capacity of the shadow fleet as evidence that sanctions have failed, while some others may advocate for a full ban on Russian access to Western maritime services to avoid the price-cap enforcement obstacles. However, both readings ignore that enforcement should no longer rely on maritime services or the shadow fleet alone, but instead can be conceived as forcing a trade-off between two shipping systems: the shadow fleet, which the EU can make scarce and costly as well as residual Western channels that, despite falling under Western authorities’ direct control, have previously allowed opportunities for sanctions avoidance. Nonetheless, it is the availability of traditional Western shipping channels that prevents measures targeting the shadow fleet from disrupting global markets: when shadow capacity is tightened, Russian barrels pour into a system the coalition can control, instead of leaving the market and lifting the world price.
A way to strengthen leverage is to target both the volume and the quality of the shadow tonnage, making Western-controlled shipping channels able to effectively impose a cost on the seller by requiring verifiable pricing or by imposing a per-barrel charge. Yet, before evaluating potential solutions, it can be useful to dissect the main turning points of the EU’s sanctions policy, to assess what the price cap and the campaign against the shadow fleet have respectively achieved.
The First Measures: Embargo and Price Cap
As a response to the invasion of Ukraine, in June 2022 the EU adopted the 6th sanctions package, which banned imports of seaborne crude from Russia and blocked European firms from providing shipping services, independently of the final destination of the tankers.
Fear that such a policy would contract the world supply of oil, and consequently let the price rise, led the G7 countries to replace it with a softer instrument: from 5 December 2022, Western services could carry Russian oil to third countries, provided it was sold at or below a price cap of $60/bbl.
A decomposition of what followed suggests that the ban and the price cap acted in different ways. Kilian, Rapson and Schipper (2026) estimate that, by March 2023, the embargo forced Russia to sell Urals crude at a discount that was roughly $32/bbl larger than in January 2022; almost half of this discount reflected the higher cost of rerouting to Indian rather than European refineries. The remainder is ascribed by the calibrated model utilised in the study to the bargaining power that India acquired after it became one of the two buyers that could absorb Russian exports. In the same month, the authors' figures suggest that sanctions cut Russian oil export revenue by about 26% (relative to the expected revenue in the absence of war), almost entirely through price rather than volume.
Still, according to the model, the price cap had a negligible effect on Russian export price: Urals did trade below $60/bbl from December 2022 to spring 2023 and again during early 2024; however, this likely reflected the embargo-driven discount combined with a fall in global oil prices from late 2022. Outside Europe the cap was widely ignored: ESPO crude, shipped from Russia’s Pacific port of Kozmino to Asia–Pacific markets, consistently traded above it because, although the cap was legally binding, it was hard to enforce.
Ultimately, the price cap had a political rather than economic purpose, since it allowed EU politicians to claim sanctions were tightened without endangering global supply through a full maritime service ban. In other words, the forces that hurt Russia in 2022-23 were freight costs and increased buyer power due to rerouting. Neither factor was dependent on the price cap and their effects decayed over time: after March 2023, as freight costs fell and Russia learned how to disguise its oil’s origin, the discount on Russian crude eroded.
The Effectiveness of the Price Cap
In July 2025, the 18th EU sanction package introduced an automatic mechanism that kept the price cap 15% below the average Urals price over the preceding 22 weeks. However, after the outbreak of the Iran war in February 2026, the Hormuz crisis critically tightened the global supply of crude. In this situation, Urals prices would have pushed the cap upward, leading to concern among member state leaders during the EU Council summit in July, 2026. To address this, they agreed to freeze the price cap at $44.10/bbl until 15 July 2027, explicitly “to ensure that Russia’s profits from oil sales remain contained”.
Urals averaged $85/bbl in May, $61/bbl in June, $57/bbl in July, and $66/bbl in August; in the same period, a quarter to a third of Russian seaborne crude was carried on tankers insured by IGP&I clubs or owned in coalition countries. Since Urals traded well above the cap while coalition-linked tankers carried a great part of Russia’s seaborne crude, there are two possible explanations: either the attested prices were unreliable, understating the actual price of purchase, or other weaknesses and gaps in the sanctions regime were exploited by traders; in both readings the cap appears to be unenforced in relation to the barrels it formally covers.
The Centre for Research on Energy and Clean Air estimates that when effectively enforced the cap would have cut Russia’s August oil export revenue by about 15% (compared to revenues absent the price cap). Johnson, Rachel and Wolfram (2026) illustrate the importance of enforcement through an economic model that simulates the price cap’s effects under different enforcement scenarios. In their theoretical framework, a fully enforced cap might encourage Russia, defined as a financially constrained petrostate, to extract and export more because it eliminates benefits from holding back supply; such a cap would therefore lower and stabilise world prices. On the contrary, when the cap can be evaded, the petrostate may decide to tighten supply and sell only through the substitute channel, profiting from the price spike that the resulting scarcity triggers on global markets.
The authors’ main conclusion is that effective enforcement is a precondition for the low level of the cap itself: in August, the $44.10/bbl cap was applied in a market where Brent was trading above $90/bbl, and it relied on an attestation system in which insurers and shipowners did not see the price actually paid, close to the condition the authors warn against.
The Evolution of the Shadow Fleet
Russia’s response to the cap was the development of outside shipping capacity; Europe's answer was to target the ships. Cardoso, Salant and Daubanes (2025) provides the tools to explain the mechanisms of this phase: the shadow fleet is understood as a capital stock that Russia accumulates whenever the gap between the cap price and the world price makes the investment on evasion capacity worth it. In this model, every tightening of the cap (including a full service ban) incentivises Russia to accelerate the build-up of the fleet; therefore, a lower cap may harm Russia in the short run, but in the long-run pushes it to rely on its own fleet and insurance network. Importantly, the conducted calibrations show that, for caps between $34/bbl and $69/bbl, a lower cap may even raise the present value of Russian profits. It is worth noting that the model is stylised and adapted to 2022, but the conclusion still matters: the debate should shift away from the price cap’s level toward specific measures against the shadow fleet.
Indeed, with the 14th package, European policy moved in that direction: the first port-access and services ban on individually listed vessels was introduced; successive measures expanded the list to 673 vessels sanctioned with the 21st package introduced in July 2026. Alongside the vessel listing, the sanctions network expanded to maritime registries providing false flags to shadow fleet tankers and to the sale of tankers; since April 2026, tanker sales must carry due-diligence obligations and a ‘no Russia’ clause that cascades through resales. Finally, member states gained the power to confiscate and sell the cargoes of detained shadow tankers.
In August 2026, however, sanctioned shadow tankers still carried 61% of Russian seaborne crude. The reason behind the ineffectiveness of the listing campaign is linked to the implication of vessel sanctions: a designated tanker loses access to European ports and services and becomes riskier to operate, but simultaneously it loses alternative employment opportunities; with few options left, staying employed by Russia becomes the cheaper alternative.
Listing seems to work best at the margin of entry rather than as an instrument to drive out ships already involved in Russian trade. Indeed, evidence shows that in the first half of 2026 the vessels joining the shadow fleet were fewer than 3 a month, rising to between 4 and 8 over the summer, while additions to Russia’s own ship registry fell from 25 in December 2025 to 3 in June 2026. Brussels cannot claim all the credit for the slowdown, since it is likely that the post-Hormuz crisis price spike made legitimate trade more attractive for tanker owners; even so, this shows that Russia cannot expand its fleet at will: enlargement depends on outside conditions, such as sanction pressure and profitability of the legitimate trade system.
A further tool used to limit shadow-fleet enlargement is the enforcement of sanctions against ‘false flags’; however, this may only shift rather than solve the underlying problem. The number of shadow vessels sailing under false flags fell from 101 in October 2025 to 45 by mid-2026: many of the ships moved to the Russian flag, which registered a growth from 280 to 382 vessels between January 2025 and June 2026; furthermore, 87% of newly registered Russian vessels were already sanctioned when they joined.
By July 2026, Russian-flagged ships represented roughly one third of the shadow fleet’s shipments, up from 2% in the previous year. The political consequence of Russian flagging is fundamental: a false-flagged tanker can be boarded, while a Russian-flagged one cannot be boarded without confronting the Russian state.
Drones Expose the System’s Limits
During the last year, the strategic limits of the shadow fleet system became visible, partly because of reasons unrelated to European sanctions.
The Ukrainian strikes cut Russian refinery runs to roughly 3.8 million barrels per day in June, with a fall of 1.6 million compared to 2025: this forced Russia to export more crude and fewer derivatives. This was further disrupted after, for nine consecutive days in August, strikes on the Sheskharis terminal stopped crude loadings at Novorossiysk.
These two episodes generated high volumes of crude surplus that could not be absorbed by the shadow fleet. In order to contain prices US Treasury licences allowed sanctioned Russian cargoes already at sea to be sold between March and mid-June: the surplus therefore moved onto western-insured tankers. In other words, sanctions enforcement comes with a trade-off: constraining Russian exports can push up world prices; once prices rose, Washington prioritised price stability and eased the restrictions.
It is worth noting that in the six months after the outbreak of the Iran war, higher world prices raised Russia’s seaborne oil and gas export revenue by an estimated €31 billion; yet the federal budget’s oil and gas revenue fell by 17.2% year on year in January-September, due to compensation payments to domestic refineries and fluctuations of the exchange rate. Yet even in this case, much of the fiscal pain inflicted on Russia came from factors unrelated to the EU’s maritime sanctions.
Disruption of the Shadow Fleet and Price Stability
The spring of 2026 was demonstrative of the result obtained by Cardoso et al. (2025), which simulated an unanticipated loss of shadow fleet capacity due to listing, detention or physical damage. In their model, Russian oil can travel through two routes: the shadow fleet or a single Western channel, made up of tankers using Western services under the price cap.
Under these conditions, if Russia still uses Western maritime services, the displaced barrels are absorbed by the Western channel at a lower price; the world price stays stable, and the present value of Russian profits falls. On the contrary, if no Western channel is in use, the loss of capacity pushes the world price up, leaving Russia better off.
In the model, even when weak enforcement and lax auditing allow cheating through Western services, Russian profits still fall, albeit by only roughly 2%. The magnitude of the changes is small, but what is important are the conditions under which the effect of pressure on the shadow fleet is borne by Russia rather than by oil consumers: redirected volumes must stay on the market, precisely in a channel where they sell for a lower price.
Johnson et al. (2026) reaches a similar conclusion, albeit with a different model: the higher the share of exports that the producer can sell escaping the cap, the sharper the trade-off between harming the producer and risking a price spike.
Two implications follow. First, the EU's most direct jurisdictional asset is its own merchant fleet: ships owned, managed or insured in EU countries are bound to EU law.
Second, leverage exists and is held by European hands, but its value depends on how it is used; currently, the EU fleet acts as a valve: it keeps the shadow-fleet scarcity from turning into a price shock, but it extracts little because the price cap is not effectively binding.
Where Leverage Survives
The instruments that the EU can still use against the shadow fleet, beyond the price cap and vessel listings, should be evaluated using two tests: whether they disrupt shadow capacity in ways Russia cannot reverse in the short run, and whether the displaced barrels are sold with a discount.
The most promising target is the inflow of tonnage, that is, the flow of tankers that join the shadow fleet. A listed ship becomes costlier to operate, but it can be replaced by a vessel purchased on the open market; restricting the inflow means acting on that replacement, limiting Russia’s ability to acquire new carrying capacity.
Every tanker entering the shadow fleet has to be bought, and European owners, brokers and financiers may find leverage in the second-hand market. Johnson et al. (2026) pushes for a sanction that discourages the sale of tankers to the shadow fleet as a way of reducing leakage; the 20th EU sanctions package goes in this direction, trying to control and target precisely that flow.
On the other hand, in the baseline model used in Cardoso et al. (2025), even a tenfold increase in the cost of enlarging the fleet lowers the present value of Russian profits by only 2.8%. This result, however, may come from a limitation within the model: shadow capacity is understood as a capital stock and, once acquired, never wears out, so any policy can only slow the expansion. Evidence shows that the Russian shadow fleet is old: in July, 93% of shadow tankers were more than 15 years old. For an ageing fleet, the binding question is whether Russia can replace hulls, and this is where controls on sales can produce harm.
The second lever is quality: ageing tankers with uncertain insurance create risk for coastal states; for example, the Russian-flagged LNG carrier Arctic Metagaz stayed adrift and uncontrolled in the Mediterranean for nearly two months after an explosion in March 2026.
Although a flag state is responsible for the safety of its ships, Russia made no effort to recover it, shifting the risk of a spill or collision onto Mediterranean coastal states.
This gives the EU leverage that does not depend on sanctions enforcement: international and EU law already allow states to inspect ships calling at their ports and detain those that lack valid insurance or fail safety standards. Requiring vessels that call at or anchor in EU waters to prove reliable insurance cover can raise the operating cost of the shadow fleet without any listing decision. Yet, ships merely transiting EU waters enjoy rights of passage, which makes checks at sea harder to justify.
Moreover, the possibilities for enforcement are constrained by Russian flag vessels: if a ship sails under it, enforcement shifts from administrative inspection to state-to-state friction.
Other targets matter less than the sanctions packages may suggest: ship managers, traders and owners can be replaced, meanwhile bunkering and crewing can be sourced elsewhere. Maritime infrastructure inside the EU is under European control, but the trade passing through it is limited and may be relocated: in August 2026, 10 ship-to-ship transfers of Russian oil in EU waters were registered, all on G7+ tankers. Hence, measures targeting either infrastructure or people working in vessels raise costs at the margin, but do not decide whether Russia can move its crude, or at what price.
The Limits of EU Action
The effectiveness of EU sanctions depends on cooperation at two levels: with partners outside the Union, and among the member states themselves. However, in 2025 and 2026, both have proved fragile.
At the external level, Washington has departed from the European position on several occasions. In June 2025, at the G7 summit in Kananaskis, Canada, Ursula von der Leyen invited all G7 partners to lower the price cap from $60/bbl to $45/bbl, as provided by the 18th sanctions package, but the United States did not back the move. Therefore, the EU and the UK cut their caps independently of Washington.
Furthermore, between March and mid-June 2026, the US Treasury repeatedly licensed the sale of sanctioned Russian cargoes already at sea in order to contain prices.
Dependence on partners is not confined to the price cap, it also affects the EU’s capacity to adopt further sanctions. The legal basis for a full maritime-service ban, adopted with the 20th package in April, makes its activation conditional on agreement within the G7 and the wider price-cap coalition. Even a united coalition would face a further limit: the buyers that matter most to Russia today are China and India; Kilian et al. (2026) raise doubts about the coalition’s ability to control ESPO flows to these countries. What the EU can do alone is enforcement and regulation of its own shipowners, insurers and waters; policies built on EU jurisdiction alone are sturdier than those requiring G7 consensus.
Acting alone, however, still requires agreement at home. Keeping European tankers in the Russian trade is in the interests of some member states: in February 2026, Greece and Malta were the main obstacle to the Commission’s proposed service ban; in May, Greek companies were five of the ten largest managers of tankers carrying Russian crude.
The answer may be not to deny the interest, but rather to price it: if European owners want to carry Russian oil, the terms should extract as much as possible from Moscow.
The Service Ban Hypothesis
The full maritime-services ban has serious advocates, and it might be the natural culmination of the path that the EU has followed since 2022. Yet, the case against using this instrument cannot be entirely dismissed.
Firstly, as previously discussed, the ban would close the channel that absorbs surplus when shadow-fleet scarcity reduces Russian capacity. In a market where a third of Russian crude is carried by coalition-linked tankers, a ban would force Russia to export less; with the simultaneous Hormuz crisis, this is precisely the outcome that Johnson et al. (2026) warns could amplify the price shock and that Cardoso et al. (2025) shows could leave Russia better off. In the model, a ban would have reduced the present value of Russia’s profits slightly less than the $60/bbl cap did, while raising the world price by 29%.
Secondly, a ban would block European owners from carrying Russian oil and would leave them holding tankers whose more valuable use might be sale to shadow operators. Unless sale controls are watertight beforehand, a ban risks giving Russia a pool of replacement ships.
Finally, the legal basis underlying the services ban requires G7 coordination, which is something difficult to achieve in recent times.
None of these arguments make a ban wrong in all circumstances: the costs depend on the state of the global market. If Gulf output recovers, the price constraint loosens, and replenishment remains the main obstacle. Therefore, a ban is a credible threat only under explicit conditions: a slack global market, strict sale controls, and G7 alignment.
EIA’s projections of Brent are at $105/bbl in the fourth quarter of 2026 and $84/bbl in 2027, so the expectations are of a continued binding price constraint.
Squeeze the Shadow, Make the Valve Pay
Accepting that the EU can neither eliminate the shadow fleet nor remove Russian oil from the market, a better strategy is to make shadow capacity scarce and expensive, ensuring that the displaced barrels pass through a western channel. Four priorities for this strategy can be identified.
The first priority is to target replacement rather than the existing stock. Success should be measured not by the cumulative number of listings, but by the monthly inflow of new tonnage into the shadow trade and the fleet’s average age.
This can be achieved by extending the 20th package’s due-diligence and notification duties to sellers, brokers, financiers and classification societies involved in tanker transfers; however, the approach works only assuming that the coalition-linked sellers supply a large share of the second-hand tankers Russia needs. If sellers in China, the Middle East or India can supply them, it will delay rather than block the enlargement. This share is the most important missing number in the European debate.
The second is to make the Western channel extract revenue from Russia: this can be achieved in two ways. The first is to keep the cap but make it binding: insurers and shipowners carrying Russian oil would have to obtain bank-verified evidence of the purchase instead of relying on traders’ attestations. The second way is to replace the cap with a per-barrel charge on coalition services used to carry Russian oil; the advantage is that a charge does not require anyone to know the transaction price, which is the weakest link in the current system. Johnson et al. (2026) argues that a financially constrained producer’s short-run supply is inelastic; therefore, much of the incidence of the charge will fall on Russian netbacks rather than on buyers (at least while shadow capacity is tight). The legal basis for this instrument is untested, but certainly the charge would have to be set below the cost of the shadow alternative to avoid pushing cargoes out of the channel.
The third priority is speed. Cardoso et al. (2025) notes that the nine-month delay of the 2022 sanctions let Russia expand its shadow fleet by about 70% and was worth roughly $19 billion in present-value terms. The EU’s habit of adopting legal bases for future measures gives Russia advanced warning: the service ban awaits G7 agreement, the transaction ban on Georgia’s Kulevi refinery takes effect only after six months, and a Commission review of a ban on LNG tanker sales is due by 25 October. Measures aimed at fleet capacity should take effect on adoption, and future bans should not be announced.
The fourth is to treat reliability as an enforcement tool: coordinated insurance checks by Nordic, Baltic and North Sea states, combined with the new power to confiscate cargoes of detained vessels, raise the cost of operating uninsured tankers. The returns from this policy diminish as more vessels adopt the Russian flag.
Grounds for a Changed Assessment
Russia will surely adapt as it has since 2022: removing ships onto its own registry, placing armed guards on board, relying more on UAE-based traders, and ordering new tankers from yards outside the EU. Therefore, the right standard for judging policy four years after the Russian invasion of Ukraine is not whether Russian oil still flows, but how much more it costs Russia to move crude, and how much of that cost Russia absorbs.
Three scenarios are possible for next year. If Hormuz reopens, prices fall and repaired Russian refineries absorb more crude at home; in this case, shadow capacity becomes slack, the western channel matters less, and a tighter regime becomes less risky. If Gulf supply stays disrupted and Ukrainian strikes keep Russian exports high, the western channel remains the valve, and closing it would be dangerous. If a negotiated pause or a US-led easing erodes coalition coordination, the expected rise in leakage would make the European replenishment control system a priority.
The strategy proposed here, making the Western channel maximally extractive of Russian revenues and starving the shadow fleet of replacement tankers, would weaken under conditions that can be verified: if Western-carried barrels turn out to be priced near the cap, the valve already extracts and reform is unnecessary; if coalition-linked sellers supply a small share of the tankers entering the shadow fleet, replenishment controls will only delay rather than constrain Russian capabilities; if the oil market is slack, a services ban becomes defensible; if Russia can expand its own shipbuilding quickly, the fleet can be refilled from sources independent of Europe, making restrictions on European tanker sales weaker.
Four years of sanctions on Russian oil have produced effects that European policy did not anticipate: Russian oil income has been cut mostly through channels the sanctions’ designers did not emphasise (freight costs, buyer power and, lately, physical damage), while the price cap, the instrument most associated with the campaign, now serves mainly to keep a Western channel open as a valve. Closing the valve while the Gulf is disrupted would work as a relief for Russia: the harder task is to keep it open and make every barrel that passes through it pay.
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