Denys Sienik, Ukraine’s chargé d’affaires in Washington, said Ukraine would present its proposals to the Trump administration and members of Congress this week. The requests include Russian companies involved in a satellite communications project modeled on SpaceX’s Starlink system and additional vessels believed to be part of Russia’s so-called shadow fleet.

The initiative comes less than two weeks after Trump signed the Lindsey O. Graham Sanctioning Russia and Iran Act of 2026 into law on Sept. 18.

The law establishes mandatory review and sanction provisions covering Russian government officials, financial institutions, defense-industry suppliers, energy interests, vessels involved in sanctions evasion and other categories of people and entities.

Ukraine targets Russian satellite supply chain

Sienik identified companies producing components for Russia’s planned satellite-internet network as Ukraine’s immediate priority.

The principal Russian company developing the network is already under U.S. sanctions, he said, but companies supplying components to the project have not all been designated.

Ukraine argues that completion of the satellite constellation could provide Russian forces with additional communications and real-time battlefield information. Sienik said Kyiv is particularly concerned about the system’s potential effect during the coming winter.

The U.S. legislation gives the administration authority to sanction foreign persons that knowingly provide goods or services to Russia’s defense industrial base. The law specifically identifies categories including advanced sensors, certain machine tools, fiber-optic technology with military applications and items on the U.S. Commerce Department’s Common High Priority Items List.

Whether particular companies connected to Russia’s satellite project meet the statutory criteria remains a determination for the U.S. administration.

Kyiv seeks tougher action against Russia’s shadow fleet

Ukraine is also asking Washington to intensify measures against vessels used to move Russian oil and other commodities in ways designed to circumvent sanctions.

The new law specifically covers foreign vessels that the president determines are being used by Russia or Russian persons to circumvent U.S. or other countries’ sanctions. It also covers certain vessel owners, operators, managers, insurers and senior crew members.

The legislation includes vessels involved in transporting Russian crude oil, petroleum products, natural gas, liquefied natural gas, uranium, coal and other specified commodities.

The law also allows the president to use certain sanctions imposed by the United Kingdom, European Union, G7 or Five Eyes countries as prima facie evidence when determining whether a vessel falls within the relevant category.

Ukraine has previously pressed international partners to strengthen enforcement against companies and vessels involved in helping Russia circumvent sanctions.

New law sets an October deadline

The new legislation requires the president, within 30 days of enactment and every 180 days thereafter, to review people and vessels that fall within specified categories and impose sanctions on those determined to qualify.

Because the law was enacted on Sept. 18, the first 30-day review period runs into October. The administration therefore faces an Oct. 18 statutory deadline for the initial review and required actions covered by the provision.

The law requires sanctions against a number of specified Russian financial institutions. Within 30 days, the president must impose at least two specified sanctions on the Central Bank of Russia and impose the statutory sanctions on Sberbank, VTB Bank, Gazprombank and other qualifying Russian state-owned financial institutions.

The legislation also provides for restrictions on U.S. transactions with covered financial institutions.

Law reaches beyond Russian entities

The legislation is designed to reach some foreign actors that support Russia as well as Russian companies and officials.

Its sanctions provisions cover foreign persons that knowingly supply specified goods or services to Russia’s defense industrial base, conduct significant transactions with Russia’s armed forces, support activities that undermine Ukrainian critical infrastructure or security, or participate in sanctions-evasion transactions.

It also contains provisions concerning Russian energy projects, including specified Arctic liquefied-natural-gas projects.

The law establishes potential measures against countries that purchase Russian-origin crude oil or natural gas or facilitate sanctions evasion. A separate provision authorizes increased duties on goods imported from Russia and duties on certain countries involved in Russian energy purchases.

The legislation gives the president waiver authority under specified circumstances, meaning the existence of a statutory sanctions category does not by itself establish that every potentially covered entity will immediately be designated.

Ukraine has been building sanctions dossiers

Kyiv’s latest requests build on a broader Ukrainian effort to identify companies and suppliers supporting Russia’s military production.

In August, Ukrainian presidential sanctions commissioner Vladyslav Vlasiuk said Ukraine had identified more than 100 Russian companies involved in ballistic-weapons production and had supplied information to partner governments. He also said Ukraine had identified more than 200 Russian plants and more than 1,600 machine tools used in weapons manufacturing.

Ukraine has separately strengthened its own sanctions against Russian financial institutions and cryptocurrency-related entities, saying the measures are intended to prevent Russia from using newer financial instruments to circumvent restrictions.

President Volodymyr Zelenskyy also discussed implementation of the Graham law with U.S. lawmakers during meetings in September. On Sept. 24, he said Ukraine needed sanctions against Russia and those helping it generate revenue from the war.

Washington must decide which requests to adopt

Ukraine’s list does not determine which entities the United States will sanction.

The decision rests with the Trump administration under the authorities and requirements established by the new law. The legislation sets categories and deadlines but leaves determinations about individual foreign persons and vessels to the president and relevant U.S. agencies.

Sienik’s proposals therefore represent Ukraine’s requested targets rather than a finalized U.S. sanctions list.

The administration’s initial decisions will also show how broadly it interprets provisions covering Russia’s defense supply chains, maritime sanctions evasion and foreign companies supporting Russian strategic industries.

For Ukraine, the immediate objective is to persuade Washington to use the new authority against companies and vessels that Kyiv says are contributing to Russia’s military capabilities or helping Moscow maintain energy revenues.

The first statutory review deadline is Oct. 18.

Reporting Credit: U.S. Government Publishing Office; Government of Ukraine and Office of the President of Ukraine; Ukrainian Embassy in Washington; U.S. Congress.

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European authorities are tracking a growing network of Russian “shadow” oil tankers that bypass sanctions by sailing under false or suspended flags. These vessels raise environmental, security, and regulatory concerns while continuing to deliver oil to international markets, including China and India. Naval and coastguard agencies face limits in enforcing sanctions at sea, highlighting the complexity of maritime law.

Tracking the Shadow Fleet

In the western Baltic Sea, Swedish coastguard officers routinely challenge oil tankers suspected of violating sanctions. Using radio calls, officers ask crews to provide details about insurance, flag state, and last port of call. One tanker, Unity, recently reported departing from Suez, Egypt, with intentions reportedly to reach Russian ports.

Jonatan Tholin, a Swedish maritime investigator, explains that such vessels are part of the Kremlin’s “shadow fleet,” a collection of tankers used to evade Western oil price caps imposed after Russia’s invasion of Ukraine. Some of these ships are suspected of engaging in illegal activities, including undersea sabotage, illicit drone launches, and location data manipulation.

Legal and Regulatory Challenges

Maritime law grants countries limited authority to intervene in international waters. Many shadow ships operate without valid national flags, effectively becoming stateless and uninsured. Michelle Wiese Bockmann, senior maritime intelligence analyst at Windward AI, warns that accidents involving these vessels, such as large-scale oil spills, could leave regulators struggling to hold anyone accountable.

The International Maritime Organization reports that the number of falsely flagged ships has more than doubled this year, reaching over 450 globally, most of them tankers. Estonian Navy head Commodore Ivo Värk notes a sharp rise in such vessels near the Gulf of Finland, a gateway to Russia’s key oil terminals, Ust-Luga and Primorsk.

Unity – A Case Study

Unity offers a clear example of how the shadow fleet operates. Originally built in 2009 as Ocean Explorer, it sailed under Singapore’s flag for over a decade. In 2019, the vessel appeared in a UN report for transferring fuel to North Korea.

Between 2021 and 2024, the tanker changed names and flags multiple times—Ocean Vela, Beks Swan, March, and Unity—with registrations in the Marshall Islands, Panama, Russia, Gambia, and Lesotho. Despite these changes, it retains a single unique IMO number. Lesotho, a landlocked African nation, does not maintain an official shipping registry, meaning the vessel’s current flag is effectively invalid.

Unity’s movements illustrate the fleet’s evasive patterns. In the past year, it navigated through the English Channel four times, often between Russian ports and India, which has not signed the oil price cap. By early November, Unity was anchored outside Ust-Luga, despite being sanctioned by the UK and EU.

Enforcement Limitations

Naval officers caution that intervention at sea is constrained. The right of innocent passage allows ships to navigate international waters, though stateless vessels technically lack this protection. Countries such as France, Finland, and Estonia have detained shadow ships suspected of criminal activity, but these operations are rare due to potential escalation.

Commodore Värk recounts an incident in May when Estonia attempted to intercept a flagless tanker, prompting Russia to deploy a fighter jet. Since then, Russian naval vessels have maintained a continuous presence in the Gulf of Finland. NATO officials note that monitoring such vessels serves as a deterrent while avoiding direct confrontation.

Global Oil Market Impact

Shadow fleet tankers continue to generate substantial revenue for Russia. The International Energy Agency reports that Russian crude and oil product sales totaled $13.1 billion in October, down from $15.4 billion a year earlier. Analysis from the Centre for Research on Energy and Clean Air indicates that shadow tankers account for 62% of shipped Russian crude oil, with China, India, Turkey, and the EU as major buyers.

Opaque ownership and frequent name or flag changes complicate tracking. Windward AI estimates that the beneficial owners of 60% of these vessels remain unknown, highlighting the difficulty of enforcing sanctions in maritime trade.

Security and Environmental Concerns

Experts warn that the shadow fleet poses both environmental and security risks. Ships with poor maintenance may cause spills or accidents. The combination of stateless operations, sanctions evasion, and proximity to sensitive infrastructure increases the potential for incidents.

Bockmann describes the situation as a visible erosion of international maritime rules. “The dark fleet is getting darker,” she says, emphasizing the stakes for both environmental protection and global security.

Russia’s Response

Russia’s embassy in London dismissed the term “shadow fleet” as misleading and discriminatory. A spokesperson argued that Western sanctions are “illegitimate” and disrupt established commercial practices. They added that invalid flags are often due to administrative delays and that restrictive regulations force shipowners to navigate a fragmented legal landscape.

Outlook

Europe continues to monitor and document the shadow fleet, balancing enforcement with the risk of confrontation. Naval and coastguard authorities emphasize that surveillance and reporting can serve as a deterrent, even when direct intervention is limited. Analysts warn that without international cooperation, shadow fleet activity may continue to challenge sanctions, maritime law, and global energy security.

Source: BBC – On the front line of Europe’s standoff with Russia’s sanction-busting shadow fleet

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Finnish authorities have detained a ship connected to Russia amid an investigation into potential damage caused to a power cable and several data cables in the Baltic Sea. The incident is the latest in a series of disruptions to critical infrastructure in the region.

The Detention of the Eagle S

On Thursday, Finnish police and border guards boarded the vessel Eagle S in Finnish territorial waters. The authorities took control of the ship’s command bridge as part of their investigation, according to Helsinki Police Chief Jari Liukku.

Although flagged in the Cook Islands, the Eagle S is believed to be part of Russia’s shadow fleet of fuel tankers. These vessels, often aging and operating with unclear ownership, were acquired to bypass Western sanctions imposed on Russia due to the ongoing war in Ukraine. These ships, which lack Western-regulated insurance, raise significant environmental concerns.

Suspected Damage to the Estlink-2 Power Cable

The Eagle S’s anchor is suspected of causing damage to the Estlink-2 power cable, which connects Finland and Estonia. Finnish media reports indicate that the cable went down on Wednesday, affecting power transmission between the two countries. This incident is part of a broader pattern of attacks on vital infrastructure in the Baltic region, including the Nord Stream gas pipelines and several data cables.

International Reactions and Concerns

The European Union’s foreign policy chief, Kaja Kallas, expressed concern over the rising number of suspected attacks on critical infrastructure. Kallas, a former Estonian prime minister, commended Finnish authorities for their quick response to the incident. She called the Eagle S part of Russia’s shadow fleet, which not only threatens security and the environment but also helps fund Russia’s war efforts. The EU is considering further sanctions targeting this fleet.

Estonian officials also responded swiftly, holding an emergency session following the cable damage. Prime Minister Kristen Michal stressed the need to enhance the protection of critical infrastructure both on land and at sea.

Growing Threat to Regional Security

This recent damage to the Estlink-2 cable follows a series of attacks on Baltic infrastructure, which has raised alarms about the systemic threat posed by these incidents. In November, two data cables—one between Finland and Germany and another between Lithuania and Sweden—were severed. Germany’s defense minister has suggested that these attacks may be part of Russia’s hybrid warfare strategy, though no specific party has been identified.

Estonia’s President Alar Karis echoed these concerns, stating on social media that the repeated damage signals a growing threat to the region. He called for coordinated action with Finland and NATO allies to address these risks.

The Nord Stream Sabotage and Ongoing Investigations

The attacks on Baltic infrastructure are not limited to power and data cables. In September 2022, the Nord Stream pipelines—vital for transporting natural gas from Russia to Germany—were damaged by underwater explosions. Investigations into this sabotage are ongoing, but authorities have confirmed that it was an intentional act.

Impact and Response

Estonia’s energy network operator, Elering, reassured the public that there is enough spare capacity to meet power demands, despite the damage to the Estlink-2 cable. However, repairs to the cable may take up to seven months, highlighting the significant disruption caused by these ongoing attacks.

As tensions rise over these incidents, it is clear that the security of critical infrastructure in the Baltic Sea remains a key concern for both regional governments and international allies.

Source

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