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Iranian-Flagged Dark Fleet: Ecological Risk Assessment - Pole Star Global​

This report analyses 29 Iranian-flagged crude oil tankers that are suspected of being part of the global shadow fleet. While not all the tankers are sanctioned we see significant gaps in AIS reporting or situations where the vessel has completely gone dark since December 15 (for the purposes of this paper we will refer to this as the Iranian dark fleet). December 15th is a significant date since it was 2 days after the capture of the first Venezuelan oil tanker by the United States. The analysis reveals significant ecological risks posed by aging vessels with substantial carrying capacity operating under reduced regulatory oversight and without Western insurance coverage.

CRITICAL FINDINGS

The combination of advanced vessel age, lack of Western insurance, and reduced maintenance standards under sanctions creates an elevated risk of catastrophic environmental damage with limited ability to hold countries, companies, or individuals responsible.

Fleet Composition

The Iranian-flagged component of the global shadow fleet consists of 29 crude oil tankers with a combined gross tonnage of 30.6 million tons and deadweight capacity of 6.75 million tons. This fleet represents a concentrated ecological risk due to several compounding factors: advanced vessel age, operation under sanctions constraints, lack of international insurance coverage, and potential gaps in maintenance and inspection protocols.

Visual Analysis

Figure 1 – Ecological Risk Assessment

Overall Fleet Risk Profile:

• All 29 vessels score Medium to High risk (no vessels below 50)
• 9 vessels (31%) are in the extreme risk category (score >75)
• Average ecological risk score: 73.4

Highest Risk Quadrant (Top-Right): 5 vessels combining old age (>20 years) + large capacity (>median tonnage):

1. ARMAN 114 – Score 94.0 | 29 years old | 156,880 GT | 300,579 DWT
2. HENNA – Score 83.3 | 23 years old | 160,930 GT | 299,242 DWT
3. HASNA – Score 83.3 | 23 years old | 160,930 GT | 299,229 DWT
4. DOVER – Score 83.3 | 23 years old | 160,576 GT | 296,977 DWT
5. DOWNY – Score 81.3 | 22 years old | 160,576 GT | 296,977 DWT

Combined threat from these 5 vessels alone:

• 799,892 gross tons
• 1.49 million DWT (~11.8 million barrels capacity)
• Could cause spill 12-13x larger than Exxon Valdez

Businesses and ports brace for headwinds amid the possibility of another trade war - ImportGenius​

On January 13, United States President Donald Trump announced a 25% tariff on Iran’s trading partners, an effort to further isolate that country amid widespread street protests. If that tariff is stacked atop existing ones for Iran’s largest trading partners, China and India, it would bring their respective tariff rates to 55% and 75%, respectively.

Five days later the President announced an additional 10% tariff on eight European countries as part of his campaign to secure ownership of Greenland. While those tariffs were quickly called off, the announcement led observers to label them Trade War 3.0, following previous trade wars in 2018 (1.0) and 2025 (2.0).

While no single policy package has yet reached the scale of the previous trade wars, the speed, unpredictability, and cumulative impact of recent announcements are already reshaping trade behaviour.

12 top seaports saw volumes shrink in rollercoaster year

Data for America’s top 25 marine ports, analyzed by ImportGenius, show that despite last year’s trade war, total TEU volumes in 2025 were 27.76 million, a number that’s exactly on par with 2024.

The data also shows that the trade war hit some ports harder than others, with 12 of the country’s top 25 ports experiencing declines in volume. For 4 of them (Wilmington NC, Mobile AL, and Seattle and Tacoma, WA) the decline was in double digits.

There are lots of nuances in the data. For instance, while the Port of Los Angeles, the second largest in the country, experienced a decline of only 1.29%, that represents 85,081 fewer TEUs arriving last year, a substantial drop. Baltimore’s increase, meanwhile, reflects its recovery from an 11-week closure in 2024 due to the collapse of the Francis Scott Key bridge.

The net result: overall U.S. import volumes held steady, but volatility intensified beneath the surface, creating clear winners and losers among individual ports.

Enforcement Shock Accelerates Dark Fleet Reflagging to Russia - Windward​

A Structural Shift in Russia’s Shadow Fleet

At least 120 falsely flagged, sanctioned tankers are likely to reflag to Russia’s registry in the coming months, as Western interdictions of stateless shadow fleet vessels accelerates a structural shift in Russia’s oil export logistics.

All ships fit the profile and trading pattern of tankers that have already switched to Russia’s flag following a governance crackdown and nine interdictions of sanctioned, stateless vessels in just over eight weeks.

Reflagging as a Response to Enforcement Pressure

Nearly 70 dark fleet tankers have been tracked by Windward broadcasting Russia as their new flag since May 2025, including 40 since the boarding, seizure, or detention of falsely flagged ships by the U.S., UK, and France began in December.

At least three vessels – Akkord (IMO 9259599), Saga (IMO 9318553), and Topaz (IMO 9292034) – switched to Russia’s flag from fraudulent registries last week alone.

Ships trading under fraudulent registries lack flag-state protection, making them subject to boarding under the United Nations Convention of the Law of the Seas.

Throughout 2025, more than 300 shadow fleet tankers involved in sanctioned Iranian, Venezuelan, or Russian oil trades shifted to fraudulent flags, often after repeated flag hopping.

These vessels were subsequently deregistered by permissive registries, including Gabon, Cook Islands, Barbados, Comoros, and Gambia, after sustained pressure to remove Western-sanctioned tonnage, leaving many ships effectively stateless.

This left the tankers vulnerable at sea. Reflagging to Russia, which is often the only registry willing to accept them, restores legal protection under international maritime law, at least for now.

Enforcement Pressure Drives Structural Shift

The trend toward reflagging to Russia is expected to accelerate if governments, including the U.S., maintain pressure and continue interdicting falsely flagged vessels.

The most recent interdiction, on February 9, saw U.S. commandos board the runaway Suezmax tanker Aquila II (IMO 9281152) in the Indian Ocean. This marked the eighth U.S. interdiction related to Venezuela, and the ninth overall since December.

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