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The number of vessels arriving in the EU after conducting a ship-to-ship transfer with Russian tankers is shrinking slower than hoped, despite the introduction of fresh sanctions in June, research suggests. 

Maritime analytics firm Windward says the number of such vessels calling at EU ports dropped by around a quarter in Q3 of 2023 compared to Q2, but says this decline is “not as high as expected given the many restrictions imposed”. 

The EU’s 11th package of sanctions against Russia, adopted in June this year, requires member state ports to deny access to vessels that have loaded crude oil or petroleum from another tanker on the high seas, or that have manipulated location transmission signals. 

The reforms followed warnings from several authorities that ship-to-ship transfers were being widely used to circumvent sanctions on Russian oil, but according to Tel Aviv-headquartered Windward, the practice has not completely stopped. 

“This is exactly the issue the 11th package (released relatively recently) is meant to solve, with a greater focus on such illicit ship-to-ship operations,” its Q3 risk report says. 

Ship-to-ship transfers are common and only rarely indicative of sanctions evasion, Windward says. It estimates that of more than 50,000 tanker-to-tanker meetings in Q3, just 1.6% were flagged as illicit activity. 

But changes in the locations of ship-to-ship transfers suggest a greater risk of Russian involvement, notes Byron McKinney, product management director for trade finance and compliance solutions at S&P Global Market Intelligence. 

He says vessels have “pretty much moved away from Q1 and Q2 hubs”, such as Gibraltar, and are now preferring the Baltic Sea and Black Sea. 

“Russian-owned firms are more likely now to be involved in this activity,” he tells GTR. 

At the same time, overall suspicious activity – including switching off or manipulating ships’ reported locations – has soared by 550% in the Baltic Sea in Q3, Windward’s report adds. 

The company also reports a 27% jump in so-called dark activity following a port call in Russia. 

The EU’s 11th sanctions package also banned the transit of cargo through Russian territorial waters, yet Windward’s data shows a slight increase in both transits and port calls for vessels leaving member state ports. 

It describes this finding as “an indication that the 11th package has not yet made the impact regulators were hoping for”. 

Outside Europe, the report finds that Egypt’s waters have emerged as a “new hub” for location signal manipulation by vessels, and that a previous hotspot for dark activity close to the Maldives has shifted towards India and Pakistan. 

Two of three ports most commonly visited after signal manipulation are in the UAE, along with Iraq’s Khor Al Zubair, it says. 

The report adds that China has now surpassed the UAE as the top destination for Russia’s shadow fleet of vessels, used to transport goods without the involvement of western companies. Q3 also saw a 33% rise in these ships calling at ports in Singapore. 

And Windward says Q3 “marked a new all-time high” of Russian oil exports to Latin America. 

“This is interesting, as we identified this continuous increase coming from one specific country – Brazil,” it says. “Since the beginning of 2023, the number of direct voyages of Russian oil to Brazil has increased by 186%.” 

Although Brazil has not imposed sanctions on Russia, Windward says there appears to be an upsurge in ship-to-ship transfers from a vessel leaving Russia to a vessel heading to Latin America. 

“Latam has seen a spike in such voyages in Q3, with an increase of 350%,” it says.