The file firms use to check whether a counterparty is under EU sanctions is, the European Commission now says, “provided for information purposes only”. It carries no legal weight and does not replace the legal acts in the Official Journal, Saul Goulding, a Commission press officer, wrote in reply to Maritime Watch’s questions. The reply followed our finding that the consolidated list leaves out 173 people and organisations sanctioned in 15 Council Regulations between 16 March and 7 August, among them Gazpromneft Shipping, Lukoil-Western Siberia and Trans KA Tankers Management. The Commission is reviewing the list but has not said when the missing entries will be added.
It's your responsibility
The reply puts the burden on the user. The law is the Official Journal; the list is a convenience, and one the Commission itself says may contain inconsistencies. For shipping, the missing entries include the ship managers Albatross, Dreamer and Orchid Shipmanagement, Volga Oil Shipping and Trans KA, all listed on 15 June. Where the law prints IMO company numbers, for 18 entries including Sovcomflot, FESCO and GTLK, the list carries one. Nine entries the Council has deleted, seven of them Syrian state bodies, are still on it. London’s list shows no comparable gap: all but two of the 550 entries the UK added in its 2026 Russia notices are on it, and those two were withdrawn and reissued on 2 October.
The growing trans-Atlantic divergence
On 8 October the US Treasury listed 22 ships, all under its Iran programmes, and the UK 12 tankers under its Russia regime; no ship appears on both. Mariel shows Washington has added no ship under any Russia-related programme since early 2025. Of the 88 ships the EU or the UK listed for the first time this year, Washington has added two since, neither under a Russia programme; 22 more were already on its list. The 30-day window in the Sanctioning Russia and Iran Act, which lets the President treat EU and UK listings as evidence, closes on 18 October.
The EU added 826 entities to its Russia list on 12 October. Among them were shipyards, repair plants and naval design bureaus in Russia and occupied Crimea, all listed because Moscow counts them as part of its military-industrial complex. No yard outside Russia, occupied Ukraine and Iran has ever been on the EU list. Washington listed the Turkish repair yards Denkar in 2023 and Bulutlar in 2024 for servicing sanctioned Russian shipping companies. Of the 14 already-sanctioned ships broken up between 2022 and 2025, eight went to Alang in India. Will the EU sanction these yards?
On film
Not every shadow-fleet tanker is an ageing hull. Our short film follows one built in 2018 and christened Crudesun. Port state control inspected her eleven times and never detained her. In October 2023 she changed name, flag and owner in a single month, and was never inspected in a Western port again. It is built from the Mariel database, and is free to watch on the Maritime Watch homepage.
Maritime Watch has reported EU maritime regulatory affairs from Brussels since 2010. The archive runs to more than five thousand articles. Mariel briefings on request, and free trials: editor@maritimewatch.eu.