Shadow fleets under sanctions: the regulations of the IMO framework

The emergence of “shadow fleets”, clandestine maritime networks designed to circumvent sanctions, poses a critical challenge to global maritime governance, safety, and environmental protection. This paper examines the regulatory response of the International Maritime Organization (IMO) to this phenomenon. It argues that, despite establishing a comprehensive framework through conventions such as the International Convention for the Safety of Life at Sea (SOLAS) and the International Convention for the Prevention of Pollution from Ships (MARPOL), the IMO’s approach remains reactive and fragmented. The Maritime Labour Convention (MLC) is also considered in light of its relevance to seafarers’ rights. The study demonstrates that shadow fleets engage in systematic violations, including AIS manipulation, illicit ship-to-ship transfers, and the operation of aging and poorly maintained vessels, thereby increasing risks to maritime safety, environmental protection, and labor welfare. The analysis demonstrates that these patterns persist due to structural constraints, including the non-binding nature of key instruments, uneven flag state enforcement, and the technical limitations of the IMO’s mandate. In response, the paper proposes a more integrated governance model, including a precautionary exercise of the IMO’s mandate, strengthened enforcement through targeted audits and transparency measures, enhanced coordination with other regimes such as the United Nations Security Council (UNSC) and the International Labour Organization (ILO), and clarification of the role of coastal states within the exclusive economic zone (EEZ). This research contributes to the field of maritime governance by bridging policy-oriented analyses of shadow fleet operations with legal scholarship, offering a political economy explanation for persistent non-compliance and providing policy-relevant insights for mitigating associated risks.