Open letter: strengthening of sanctions on oil of Russian origin – Ecoclub Rivne is an environmental NGO

Open letter: strengthening of sanctions on oil of Russian origin

Open letter: strengthening of sanctions on oil of Russian origin

President of the EU Commission Ursula von der Leyen

Secretary of State Antony J. Blinken, USA Department of State

EU Energy Commissioner Kadri Simson

Prime Minister of the United Kingdom Rishi Sunak

Prime Minister of Denmark Mette Frederiksen

Prime Minister of Finland Petteri Orpo

Prime Minister of Norway Jonas Gahr Støre

Prime Minister of Greece Kyriakos Mitsotakis

Prime Minister of Malta Robert Abela

An open letter to politicians, officials and the public concerning the strengthening of sanctions on oil of Russian origin and the serious threat of Russia’s shadow tanker fleet to water resources and the inhabitants of maritime states

We sincerely thank you for your comprehensive support of and assistance to Ukraine in confronting the aggressor and jointly defending European values, rights and freedoms from Russian aggression, which has destroyed peace in Europe and still threatens the entire European community with further escalation. The fight for peace and stability in Europe takes a heavy toll on every Ukrainian every day.

As representatives of civil society in Ukraine and Europe, we are extremely disturbed that Russia’s activities are not aimed at stopping the war against Ukraine, which was the reason for the imposition of sanctions, but at avoiding the sanctions previously imposed on Russian oil, which now poses huge risks of environmental disasters in different parts of the world, and in the territorial waters of European countries and Ukraine in particular.

Russia’s oil exports by sea grew in 2023, and at the end of the year, the country is still one of the five largest oil exporters in the world with revenues of more than €110 billion a year (in 2022). The profits generated from oil trade are used to continue the war against the people of Ukraine, destroy cities and infrastructure, spread propaganda around the world, and organise new cyberattacks.

Although the EU imposed a ban on the import of Russian oil by sea in mid-2023 as part of the 11th package of sanctions, the Russian oil and oil products continue to be exported in significant volumes, including to the EU, mainly through the Baltic and Black Seas. In addition, Russian oil is transited through the territorial waters of European countries such as Estonia, Finland, Denmark, Germany, France, Norway, Greece, Malta and the United Kingdom. To deliberately evade compliance with sanctions on maritime oil supplies and price ceiling restrictions on Russian oil, the owners of the energy resource, mainly the state-owned Rosneft, or intermediary companies, use grey and black shadow fleets consisting of obsolete and decommissioned tankers to transport Russian oil, as well as dubious insurance companies to insure against the risks of emergency events, in particular, environmental disasters that may be caused by such vessels.

The number of grey and black shadow fleet tankers used for oil shipping in Russia has already reached more than 2,000 ships, of which 1,100 are used for black operations. These vessels often disable the AIS identification system (which helps to avoid collisions) while loading oil, and at sea, change the location and engage in other extremely risky shipping practices. Furthermore, STS transfers (transferring oil from one vessel to another right at sea) and concealing the true prices of the sold oil through price manipulation are often observed.

We welcome the European Union’s decision to introduce the 12th package of sanctions, which provides for restrictions and greater control over Russian oil exports. We would like to emphasise that Russia’s evasion of the imposed sanctions does not contribute to achieving the goal of ending the armed aggression against our country, and therefore requires a more radical step. As part of the next package of sanctions, we call for Western countries to impose the embargo on any Russian oil and oil products, and to strengthen control over previously imposed sanctions, which should be applied when preparing a new package to mark the 10th anniversary of the annexation of Crimea and the beginning of the Russian war in Ukraine in 2014.

On unprecedented damage to marine ecosystems and maritime states

Given the high risk of subsequent confiscation of an outdated vessel, which usually operates without proper insurance, regular technical inspection, or legal encumbrance, in most cases, Russian oil is transported by the tankers belonging to third countries, some of which are blacklisted in the shipping industry. Thus, in the event of oil spills from Russian black fleet tankers, coastal states will almost never be able to receive compensation for environmental damage. The scale of the danger is impressive, as about 300 such vessels loaded with Russian oil transit European territorial waters every month.

A large-scale man-made disaster almost occurred with a ship carrying Russian sanctioned oil when, in May 2023, an outdated 18-year-old shadow tanker carrying 340,000 barrels of Russian oil almost crashed into a stationary Danish navigation lighthouse in Danish territorial waters, 1.5 km from the beaches of the Langeland coast, due to a broken propulsion system.

This year, in February, the outdated oil tanker MT Princess Empress sank near the coast of the Philippines with 5,000 barrels of oil on board, some of which spilled into the open sea. More than 200,000 people in the Philippines have been affected by the intense oil spills, not to mention the damage to the ecosystems and marine life

A similar breakdown incident took place in May this year with the 27-year-old 700,000-barrel tanker Pablo, which exploded and subsequently sank off the coast of Malaysia. Not long before that, Pablo had allegedly delivered sanctioned Russian oil to China.

In order to increase oil exports to China, disregarding the safety of international shipping and international environmental conventions, for the first time in 2023, the Russians allowed oil tankers without enhanced icebreaking capabilities to navigate in the Arctic waters, which increases the risk of accidents tenfold and can result in the irreversible destruction of sensitive Arctic ecosystems.

Due to the growth of maritime transportation of Russian oil, in addition to oil leaks from old neglected vessels, collisions between faulty tankers and accidents resulting from deliberate violations of international shipping regulations (more than 40 cases involving black tankers have been recorded in the year and a half since the start of Russian full-scale invasion), there may be significant oil spills into the seas because of frequent transfers of Russian oil between tankers in the open sea, which is carried out to avoid the price ceiling and disguise the country of origin of oil. Obviously, this is done without proper control. The International Maritime Organisation’s (IMO) Legal Committee has pointed out the risks and consequences of STS oil transfers in the open ocean. The IMO recognises the high risks of oil spills in extraterritorial waters during oil transfers. As per the IMO, the use of the black fleet to evade sanctions and violate rules and regulations can have enormous consequences for nature and the global shipping industry.  Greenpeace also believes that the substantial increase in Russian oil transportation by sea causes air pollution due to harmful CO2 emissions, and noise pollution has a negative impact on marine animals and their migration routes.

Taking into account the emergency situation with environmental threats, especially to marine ecosystems, we appeal to the Danish Government to strengthen control over the safety of navigation of all ships transporting oil in the Baltic Sea. We also call on other countries to support the safety of navigation in the Black Sea.

In addition, we insist on initiating a broad public discussion on the international environmental impact assessment and possible long-term consequences of the actions of Russian beneficiaries of the oil maritime trade. Moreover, we strongly advocate for strengthening measures to protect the fragile nature of marine ecosystems from potential damage.


1. NGO Energy Agency Alternative

2. NGO Social Initiative City of the Sun

3. NGO Rivne Social Partnership Center

4. NGO Agency of Journalistic Investigations Fourth Estate

5. NGO All-Ukrainian Sustainable Development & Investment Agency

6. NGO Hromadske Volyn

7. NGO Razom We Stand 

8. NGO Ecoaction

9. NGO Khmelnytskyi Energy Cluster 

10. Energy Transition Coalition 

11. ZMINA Human Rights Center

12. Rivne oblast organization of the All-Ukrainian NGO Civil Network OPORA

The letter was prepared within the framework of the project Monitoring and pushing for sanctions against Russian energy sources with the support of the Grassroots foundation