Washington now has a ready-made shortlist for shadow-fleet sanctions, and Europe wrote most of it. A US law signed on 18 September lets the President treat an allied listing as prima facie evidence against a ship. The allies named are the UK, the EU, the G7 and the Five Eyes. The test is whether the ship moves Russian cargo to circumvent sanctions. The four allies list 785 ships under their Russia measures, the Mariel database shows. Of those, 503 are not on the US Treasury's list under its Russia-related programmes, and the EU and the UK both list 380 of them.
Inside Mariel
Those counts come from Mariel, Maritime Watch's enforcement database. It holds records on 39,910 ships. They include 144,457 port state control inspections in the Paris MoU region since January 2018, and more than 10,000 detentions reported by the Tokyo, Indian Ocean, Black Sea and Riyadh MoUs. Against them sit the sanctions lists of nine jurisdictions, the UN included: 2,185 ships, 17,200 companies and 22,512 individuals. Everything is keyed on IMO ship and company numbers, so a hull can be followed from the list to the port to the manager. The question is one other lists don't answer: where do sanctioned ships, and the companies behind them, turn up after the listing? Mariel was behind this autumn's reporting on the Iranian tanker carousel, the Trans KA tankers and this week's US count. Briefings on request: editor@maritimewatch.eu.
The evidence test
What a listing may rest on was also before Europe's General Court. On 30 September it annulled the EU's November 2024 listing of Islamic Republic of Iran Shipping Lines. The evidence file held 20 documents, mostly press and think-tank articles and posts on X. Judges found it did not prove that the navy was turning IRISL ships into drone carriers, or that the line had carried military cargo "for years". The line stays listed all the same. Judges upheld the July 2025 decision, based on two IRISL-linked ships carrying sodium perchlorate, a missile propellant precursor, from China to Iran. Two Lloyd's List Intelligence reports named IRISL as ultimate owner of the ships' registered owners. Press reports remain admissible, the court said, if they come from several sources and are "sufficiently specific, precise and consistent".
On the ETS revision, Matteo Ricci, the Italian Socialist MEP drafting the European Parliament transport committee's opinion, would rewrite the proposed container discount. The Commission offered it only to ships of 10,000 TEU and above, according to the share of boxes they unload for onward shipment outside the EU. Mr Ricci would extend it to all container ships on voyages of more than 3,000 nautical miles into or out of the EU, rising with distance. Lines would surrender allowances for 45% of emissions at 3,000 to 4,000 miles, falling to 15% beyond 9,700. Europe's private terminal operators want the Commission's method kept, but extended to ships from 5,000 TEU and to outbound voyages. Committee amendments are due on 6 October.
Correction: The EU has removed from its reasons for sanctioning Trans KA the claim that the operator's tankers lacked adequate insurance; the Council made the change on 22 September. We have asked the EEAS and the ships' former insurers why.
Maritime Watch has reported EU maritime regulatory affairs from Brussels since 2010. The archive runs to more than five thousand articles. There is much more on maritimewatch.eu, including:
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Free trials on request: editor@maritimewatch.eu.