UK Completes Legal Review to Allow Dark Fleet Seizures
A mystery has been solved this week, explaining why the United Kingdom has been forward-leaning in providing support both to the United States and to France in their interceptions of dark fleet tankers - without participating in these seizures themselves.
The UK aided both the U.S. chase of the Russian-flagged Marinera (IMO 9230880) and the French seizures of the Comoros-flagged Grinch (IMO 9288851) in January and the Mozambique?flagged Deyna (IMO 9299903) last week. Similarly, while Finland, Sweden, and Estonia are actively seizing suspect ships in the Baltic, Russian dark fleet tankers have continued to sail unmolested through the heavily used English Channel, where tracking the movements of tankers is relatively easy. In January alone, Lloyd's List tracked 23 dark fleet tanker transits through the English Channel. Moreover, while the United Kingdom is not seizing dark fleet tankers, it is morally not possible to call upon others to do so, particularly those countries in whose waters the dark fleet anchors up and concentrates.
According to a report in the Daily Telegraph, the Royal Navy is about to commence the seizure of dark fleet tankers, now that a legal review has taken place and a legal framework has been put in place. The legal framework has not needed new legislation to supplant laws already in place since 2018, so it is not clear why this has not been done beforehand. But the framework now sets out the legal justification and the necessary procedures for seizures in a variety of circumstances, depending on the particulars of each vessel encountered. The scheme appears to cater for the legal processes both to seize cargoes for resale, and to prosecute masters and crews for health, safety, manning, and registration breaches.
The UK could certainly improve the effectiveness of its anti-sanctions activity. Although making much of the large numbers of ships and entities cited, connected with both Iran and Russia, since the present government came to power in July 2024, the UK Treasury's Office for Financial Sanctions Implementation (OFSI) has levied fines totaling only £1,410,500 ($1.88 million). These six meager penalties were all associated with breaches of Russian sanctions, and none penalized those breaching Iranian-linked sanctions. In comparison, the U.S. Treasury's OFAC levied fines totaling $262.64 million in 2025 alone. Heavy reliance on “voluntary” compliance means that the UK is neither bearing down on state-sponsored sanctions-evasion networks nor on those unscrupulous entrepreneurs who deliberately set out to evade sanctions as a route to bumper profits.
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This procedural approach to dark fleet seizures is characteristic of many strands of policy driven by the current UK government, which is led by a lawyer whose closest political ally is his long-standing friend, the Attorney General Richard Hermer, a strong advocate for international law. This legalistic approach to government is reflected in a number of maritime-flavored areas, for example, the drive to surrender the British Indian Ocean Territory to Mauritius, methodologies for stopping cross-Channel small boat crossings, and limiting direct involvement in the current war with Iran.
Nonetheless, a legalistic approach to dark fleet tankers may have some merit if it overcomes some of the obstacles that the more active nations have already encountered in their own courts when implementing seizure policies. Moreover, finding an additional and alternative source of finance for Ukraine would help circumvent obstacles put up to government aid packages by Russian sympathizers in both Europe and North America. But the UK faces another particular problem in implementing a tougher policy: will there be any Royal Navy ships or crews available to carry out the seizures at sea? Perhaps some of the prize money raised by selling off impounded cargoes ought to be used instead to buy a few more ships for the Royal Navy.
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