14 Tankers, 418 Hours, No Stops

Somewhere off the Bulgarian and Romanian coasts, the ships keep coming through. They arrive in the Black Sea, move through EU waters, and leave again. Between January and August 2026, at least 14 tankers identified as part of Russia's shadow fleet spent a combined 418 hours in the waters of those two EU member states, according to a Greenpeace Bulgaria investigation using Lloyd's List Intelligence tracking data (Greenpeace Bulgaria, Fakti).

None was stopped. None was boarded. None was detained.

That looks, at first glance, like a failure of enforcement. It may be. But the legal machinery matters here. The EU can put ships on sanctions lists. Coastal states still need a lawful basis to interfere with a vessel moving through their waters.

Why presence alone can't justify detention

The 14 vessels appear on Lloyd's List's shadow-fleet database, which identifies tankers linked to deceptive practices around sanctioned oil cargoes (Greenpeace Bulgaria). But the published material does not set out vessel-by-vessel tracks, cargo histories, insurance details, or evidence that any of the 14 entered port, transferred cargo, or caused pollution in Bulgarian or Romanian waters.

That matters because international maritime law protects what is known as innocent passage. Under the UN Convention on the Law of the Sea, ships may pass through another state's territorial sea without interference if they are not doing anything that threatens the coastal state (UNCLOS). A sanctions listing does not, by itself, cancel that right. A tanker crossing the Black Sea without stopping or moving cargo keeps the same passage rights as any other ship. As SWP Berlin has put it, listing a vessel creates political pressure, but it does not create a universal right to seize it (SWP Berlin).

Greenpeace has put the Kairos at the centre of its campaign. The sanctioned tanker was abandoned near Burgas, and activists painted its hull after satellite imagery showed slick-like traces nearby (Greenpeace Bulgaria Kairos, Cherno More). Bulgarian maritime authorities said later checks found no active pollution. That argument is still unresolved.

Where enforcement works and where it doesn't

Romania's answer shows the gap between port enforcement and sea-lane reality. The Romanian Naval Authority said no sanctioned vessel had entered Romanian ports after its listing date (DottoTV, Radio Constanta). That deals with one question: port access. It does not deal with what passes through Romania's exclusive economic zone, the wider offshore area where a state has rights over resources and pollution control, but not the same authority it has in territorial waters.

ProTV reported that Romania's Coast Guard had received more than 1,200 ship-to-ship transfer notifications since May 2022. The Coast Guard said inspections were not needed because the ships had notified under pollution-prevention rules (Stirile ProTV). In practice, notification was treated as compliance.

Denmark shows the difference when a state uses the powers it has at ports, anchorages and chokepoints. Sitting on the Baltic route, Copenhagen recorded 292 journeys by shadow-fleet tankers through Danish waters in 2025 (gCaptain). Danish authorities inspected 79 tankers at the Skagen Red anchorage and detained four (Sofart). Denmark also brought in insurance-certificate checks for loaded tankers leaving the Great Belt, feeding missing paperwork into sanctions work (Folketinget). Enforcement has teeth at anchorages and chokepoints. In open water, ships are much harder to touch.

The service levers that could make sanctions bite

The more powerful pressure point is not off Bulgaria or Romania at all. It sits in Athens and Valletta, where shipping services, ownership structures and commercial expertise matter more than patrol boats. Greek-linked operators earned at least $3.8 billion over three years from the Russian crude trade, according to Financial Times analysis (Fortune Greece).

When the EU's 21st sanctions package tried to restrict maritime services such as insurance, brokering, ship management and finance, Greece blocked the deal until it secured carve-outs for Russian LNG transport (Naftemporiki, News247). EU sanctions need unanimity in the Council, where all 27 member states must agree. Greece used the leverage that rule gives every capital.

The EU has kept adding ships to its sanctions lists. The 21st package also gave member states new powers to confiscate cargo from detained shadow-fleet vessels (Skuld, Gard). But cutting European maritime services has a cost. It can push cargoes towards older vessels, opaque flags and non-Western insurers, making the fleet harder to track and less safely insured (Brookings).

The 14 tankers and their 418 hours show the shape of the problem. The EU has built sanctions rules for the shadow fleet, but left coastal states to carry much of the environmental risk. Bulgaria and Romania face ageing, under-insured vessels moving through their waters. Greece holds some of the service levers that could squeeze the economics of the trade. Surveillance is being allowed to stand in for enforcement. Until Sofia and Bucharest use the tools Denmark has shown can work, including anchorage inspections, insurance checks and clear pollution triggers, they will keep counting the hours as the tankers pass.