Gonzalo Saiz Erausquin

The trade in pianos highlights the challenges Japan faces in enforcing sanctions in the context of complex global supply chains.”

Direct measures against those agencies that supply the shadow fleet with personnel are apparently even more complicated. In principle, the provision of crews for sanctioned ships of the shadow fleet is prohibited in the EU, but enforcement is weak, and the scope of due diligence obligations for non-sanctioned ships is often a gray area, says maritime security expert Gonzalo Saiz of the British think tank Royal Services Institute. "Crewing agencies can always argue that they knew nothing about the ownership of the ship or its ties to Russia."

Dealing with the dark fleet is not always illegal. The EU has sanctioned 68 individual tankers carrying Russian oil and it would be against its rules to crew them, though others on the Lloyd’s register are allowed to export Russian oil to non-EU countries provided it is sold below a certain price. But both legal and illegal exports aid Russia’s war economy and raise issues of national security, as well as environmental concerns, said Gonzalo Saiz, a maritime specialist at the Royal United Services Institute, a London think tank.