Hunting the Ghost Ships: The Netherlands Moves to Seize Russia's Shadow Fleet

On January 22, French commandos rappelled from a helicopter onto the deck of an oil tanker called the Grinch as it sailed through the western Mediterranean. The ship, loaded with Russian crude from the Arctic port of Murmansk, flying the flag of the Comoros Islands, and blacklisted by the EU, UK, and United States, was diverted to the Gulf of Fos-sur-Mer, its Indian captain detained, and a judicial investigation launched.

It was the second time in four months that France had intercepted a suspected Russian shadow fleet vessel. President Emmanuel Macron's message was unambiguous: "We will let nothing pass."

Six days later, the Netherlands announced it would no longer let things pass either.

A Legal Gap in the North Sea

On January 28, caretaker Ministers Robert Tieman (Infrastructure and Water Management) and David van Weel (Foreign Affairs) sent a letter to the Tweede Kamer (House of Representatives) announcing that emergency legislation is being drafted to allow the Dutch authorities to take action against ships in the Russian shadow fleet operating in the Netherlands' Exclusive Economic Zone (EEZ), the vast stretch of North Sea that extends well beyond Dutch territorial waters.

The proposed laws would grant authorities the power to systematically inspect vessels sailing under false flags, escort them to anchorage, and, in extreme cases, confiscate them entirely.

"Met de schaduwvloot financiert Rusland zijn oorlogsmachine in Oekraïne en worden internationale sancties omzeild. Dat is onacceptabel."

"With the shadow fleet, Russia finances its war machine in Ukraine and international sanctions are circumvented. That is unacceptable," said Minister Tieman. "As Europe, we have already taken many steps to counter this, but more is needed. With these steps, we want to take tougher action in the future when this type of ship passes through the Dutch part of the North Sea."

The legislation is being fast-tracked with the aim of reaching the Tweede Kamer before the summer recess. A parliamentary majority had already requested such measures in October, following a motion by D66.

What is the Shadow Fleet?

Russia's so-called shadow fleet consists of hundreds of aging, poorly maintained tankers that transport sanctioned Russian oil to buyers in China, India, and elsewhere. Operating through opaque ownership structures in non-sanctioning states, they fly flags of convenience or outright false flags, and routinely disable their Automatic Identification Systems to evade detection.

By the end of 2025, an EU analysis identified nearly 600 vessels on sanctions lists. In December alone, the EU sanctioned 41 additional ships. Yet a November 2025 report from the Helsinki-based Centre for Research on Energy and Clean Air found that more than 100 Russian vessels flew false flags in the first nine months of the year, transporting roughly 11 million tonnes of oil worth €4.7 billion. The fleet is estimated to generate around $100 billion annually for Moscow, money that flows directly into funding the war in Ukraine.

The Dutch Problem

The Netherlands has a specific vulnerability. Within territorial waters (the zone extending 12 nautical miles from the coast), states have broad powers to stop, board, and inspect ships. But in the EEZ, which stretches much further, the legal framework is fundamentally different. Under the United Nations Convention on the Law of the Sea (UNCLOS), jurisdiction over a vessel in the EEZ belongs primarily to its flag state.

This is precisely the gap the shadow fleet exploits. A ship flying the flag of Comoros, Gabon, or Palau (countries with minimal maritime oversight) effectively places itself beyond the reach of the coastal state's enforcement powers. And when a vessel flies a false flag, one to which it has no legitimate connection, it becomes technically stateless, creating a legal grey zone that until now has left Dutch authorities largely powerless.

The problem is not theoretical. In November 2025, the Dutch Navy had to escort the Russian intelligence-gathering vessel Yantar out of the Dutch North Sea after it was observed operating near critical undersea infrastructure. HNLMS Snellius and HNLMS Friesland monitored the ship, which was also suspected of mapping underwater cables, gas pipelines, and wind farm control systems. The Defence Intelligence and Security Service (MIVD) has warned repeatedly that Russian research vessels are conducting a systematic programme to identify targets for potential sabotage.

Yet throughout 2025, the Netherlands did not conduct a single inspection of shadow fleet vessels in its EEZ, even as countries like Finland, Denmark, Germany, and the United Kingdom were actively doing so. When NOS reported this in August, D66 parliamentarian Jan Paternotte responded bluntly: "It seems as though the government doesn't find it important enough, and that is very strange given that the government keeps saying how dangerous the situation with the Russian shadow fleet is."

France Shows What Enforcement Looks Like

The contrast with France could not be sharper. In late September 2025, French naval forces boarded the tanker Boracay off the Atlantic coast, an operation Putin publicly denounced as piracy. The ship's Chinese captain faces trial in February.

Then came the Grinch. The January 22 interception, conducted with British intelligence using radar tracking from Gibraltar, confirmed the ship was falsely flagged, rendering it stateless and legally open to seizure. Zelenskyy praised the operation: "Russian tankers operating near European shores must be stopped."

For the Netherlands, France's assertiveness underscored an uncomfortable truth: one of the world's most important maritime nations was watching from the sidelines while others enforced rules it had helped to write.

What the New Laws Would Change

The proposed Dutch legislation targets the specific legal gap in the EEZ. Under current law, authorities cannot board or inspect vessels in the EEZ without consent from the flag state. If a ship is flying a false flag, meaning no flag state exists, there is no one to ask for permission, and current Dutch law does not provide a clear legal basis for unilateral action.

The new framework would change this by establishing that falsely flagged vessels have forfeited the protections normally afforded to ships in the EEZ. Authorities would then be empowered to board, inspect documentation and insurance papers, escort the vessel to a designated anchorage, and ultimately confiscate it if necessary.

The ministries of Infrastructure and Water Management, and Justice and Security are working on the legislation jointly. The ministers' letter to parliament also indicates they are studying French legal frameworks, suggesting the Netherlands may model its approach on the provisions that have already allowed Paris to act so decisively.

The Bigger Picture

The timing is notable. The announcement comes days after the new coalition agreement, "Aan de slag", pledged €19 billion in additional defence spending and placed European security at its centre. While the shadow fleet legislation predates the coalition talks (the D66 motion dates to October), its acceleration fits the incoming government's stated ambitions.

It also reflects a broader European reckoning. Baltic Sea cable sabotage, Russian hybrid warfare, and the environmental risks of uninsured aging tankers have shifted the political calculus. When Finland detained a Russian-linked tanker after it damaged undersea power cables in December 2024, the era of treating shadow fleet vessels as someone else's problem effectively ended.

For the Netherlands, home to Europe's largest port in Rotterdam, a critical node for transatlantic data cables at Eemshaven, and growing offshore wind infrastructure, the stakes are especially high.

Whether the legislation arrives before the summer, and whether Dutch authorities have the naval and coast guard capacity to enforce it, remain open questions. As retired Vice Admiral Ben Bekkering noted in August: "To inspect papers on international waters, you need permission from both the flag state and the captain. A shadow fleet ship isn't exactly going to drop anchor voluntarily."

The new laws would make voluntariness irrelevant. That, at least, is the plan.