Panama tightens grip on STS oil transfers in crackdown on Russia’s ‘shadow fleet’

Rules & Regulation

The Panama Maritime Authority (PMA) has decided to strengthen the ship-to-ship (STS) oil transfer operation requirements for tankers flying the country’s flag to “shut the door” to Russia’s so-called shadow fleet.

As disclosed, the decision was made to address two vital issues at once: the operations of Russia’s dark fleet and the need to ‘bolster’ Panama’s international standing as a “responsible” Flag State.

The regulation, which is effective immediately, mandates that all units flying the flag of Panama with a gross tonnage of 150 or more notify the state at least 48 hours in advance of any planned STS operations. Technical, logistical and operational information would have to be submitted as part of the notice, the PMA has explained.

According to the Panama Maritime Authority, the notification needs to include identification details regarding participating ships, coordinates and estimated time of the ship-tp-ship transfers, the type and quantity of hydrocarbons that would be transferred, the preferred transport method (underway or anchor) as well as the confirmation of the STS plan per Regulation 41 of the MARPOL convention.

What is more, it is understood that ships will need to have their STS plans updated regularly to reflect the new notification requirement and retain onboard electronic acknowledgment as proof of receipt.

“This initiative addresses the growing use of opaque vessels to circumvent international sanctions, transport undeclared crude, or evade environmental safety regulations—practices commonly associated with what is known as the shadow or dark fleet,” explained Deputy General Director of Merchant Marine, Rina Berrocal.

“This is not just about safeguarding the reputation of the Panamanian registry, but about ensuring that our vessels are not used as platforms for illicit activities that undermine global trade and harm the environment,” she added.

In spite of numerous efforts, Russia’s shadow fleet, or dark fleet, presses on with its operations, exploiting loopholes and vague ownership structures. This has kept the country’s oil exports afloat even in the face of mounting penalties.

Beyond Panama, ‘closer to home’, Russia was repeatedly sanctioned by the European Commission via a number of measures aimed at ‘weakening’ the dark fleet.

The EU imposed the 15th sanctions package on Russia in December 2024, whereby at least 52 more ships were targeted. This action was followed by the 16th package, which was unveiled in February this year, adding 74 more units and rounding the total number to 153 of total listed vessels.

Less than three months later, namely in May 2025, the commission unpacked the ‘biggest, single G7 action’ against Russia’s dark fleet, opting to include another 189 vessels in the list, with the total now standing at 342 units.

As informed, the ships were identified in collaboration with the EU Member States and the European Maritime Safety Agency (EMSA). They are now subject to a port access ban and a ban on the provision of services.

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What is more, in December last year, Denmark, Estonia, Finland, Germany, Iceland, Latvia, Lithuania, the Netherlands, Norway, Poland, Sweden and the United Kingdom declared they would work together on ‘cranking up’ the pressure on Russia, with the initial step proposed being ship insurance.

To be specific, the twelve-nation-strong consortium said they would mandate their maritime authorities to request ‘relevant’ proof of insurance from suspected shadow vessels as they pass through the English Channel, the Danish Straits of the Great Belt, the Sound between Denmark and Sweden, and the Gulf of Finland. It is understood that the data collected would be acted upon via a joint effort.

In April 2025, the European Commission revealed that, going forward, all vessels sailing European waters would need to provide proof of insurance.