and at the start of 2025 showed no sign of let up and continues to be a challenge for all those involved in international shipping. As the Russia-Ukraine war extends into its third year, politicians and regulators have remained alive to Russia’s efforts to avoid sanctions. From a maritime perspective, efforts are being increasingly directed against the so-called “dark” or “shadow” fleet transporting Russian oil. This ‘dark’ fleet reportedly numbers some 180 vessels which have caused concern due to their age, quality of maintenance and lack of recognised insurance, particularly for pollution. The US, UK and Europe have recently introduced sanctions against this fleet, but this is, in effect, just a further step in increasing pressure from regulators to prevent owners inadvertently selling ships into the shadow fleet.
The introduction of UK OTSI (the Office of Trade Sanctions Implementation) and the Trade Aircraft and Shipping Sanctions (Civil Enforcement) Regulations 2024 demonstrate an increased appetite to find and prosecute those who breach or evade sanctions. Although headlines are dominated by Russian-targeted sanctions, it must be remembered that strong sanctions against states, individuals and entities exist relating to Iran, North Korea, Syria, Libya, Myanmar and many more.
All participants in the shipping industry must ensure they have robust policies and procedures in place to ensure that effective due diligence checks are made on counterparts, trades, cargoes, ship to ship transfers and vessel acquisition and disposal, and that strong compliance programmes are in place and are effective to guard against inadvertent breach. Parties attempting to evade sanctions have become increasingly sophisticated in their approach. All companies must be on their guard against this.
Key Takeaways
2025 will be a further period of huge change and challenge for all participants in the shipping industry. Shipping will become more expensive for users as EU regulations increasingly affect ship owners and operators. However, with this change comes opportunities. Increased co-operation between ship owners and operators is going to be key in the year ahead as the industry gets to grips with new regulatory, technological and emissions-based issues which need to be factored into day to day commercial and administrative operations.
Whilst marginal increases in efficiency and reduction of consumption will help ship operators to comply with a number of new obligations in the short to medium term, the aims of industry regulators
will only be achieved through technological developments in new fuels, energy storage, carbon capture and radical new designs of ships. Vision, finance and a certain amount of courage are going to be required if the challenge is to be met. And, in the meantime, the industry needs to ensure that it complies with the ever-increasing regulation and the increased appetite of regulators to take enforcement action.
On top of all this, there are the increasing geo-political risks due to wars in Europe, and the increasing hostility of some state and non-state actors to international shipping – these issues must remain close to the top of concerns for the industry. With these ongoing threats, there is a constant worry about getting good people to sea to crew the increasingly sophisticated ships. And human rights at sea campaigns are throwing light onto a dark and often deeply unpleasant aspect of the industry, with modern slavery being a concern.
And yet, despite all this, 2024 was a good year for shipping which economically is in rude health. Posidonia 2024 and other events were happy and optimistic. Shipping has survived all sorts of crises over the many centuries it has operated and seems in good shape to weather the many challenges that 2025 and beyond will present.
THE REPORT | MAR 2025 | ISSUE 111 | 57
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