Port state control
Fighting shadow fleets, protecting the environment and improving maritime security
There is growing concern about bad actors at sea, and with good reason. In November 2024, the Chinese bulk carrier Yi Peng 3 was suspected of intentionally dragging its anchor to sever a submarine communications cable in the Baltic Sea. In January 2025, the United States (US) Department of the Treasury announced additional sanctions on Russia’s ‘shadow fleet’ of oil tankers. In the same month, a Reuters exposé detailed the fleet of ghost vessels which Iran uses for evading sanctions. These actions are worrying in their own right, and there is strong evidence that the vessels used to carry them out pose significant environmental risks too. As Elisabeth Braw describes for the Atlantic Council, they are more likely to be older, poorly maintained, or operating with fraudulent documents or insufficient insurance, and to generate serious accidents as a result. If the ship in question is a fully loaded oil tanker, the results could be catastrophic. Reports of ghost fleets and cable cutting might prompt visions of commando raids and ship seizures in response. But an obscure piece of international regulation offers policymakers a tool which can help to tighten the noose around these vessels, lower the risks of environmental catastrophe and serve European foreign policy goals, all without having to recreate scenes from Captain Phillips.
States use port state control to monitor ships’ compliance with international maritime regulations. Historically, this responsibility fell to flag states – that is, the country in which a ship is registered and under whose flag it sails. But, after the Second World War, ship owners increasingly began to register their vessels in countries which lacked the regulatory capacity to enforce compliance. At the same time, a series of environmental disasters at sea made clear the risks of failing to police ship quality rigorously.
Port state control was implemented in response. It gives port states the authority to check ships for regulatory compliance, and to detain them and prevent them from sailing to their next destination if they do not meet necessary standards. To share the burden of conducting these inspections, prevent freeriding and avoid excessive disruptions to free trade, European states created the Paris Memorandum of Understanding (MOU) – the world’s first intergovernmental organisation aimed at coordinating port state control inspections. It entered force in 1982, and covered 14 European states; now, along with eight other regional MOUs, almost every coastal state in the world participates in some form of organised port state control. These MOUs specify rules for allocating inspection responsibility across states and define which international regulations ships must comply with.
Vessels which have been explicitly sanctioned, like those identified by the US Department of the Treasury in January 2025, or the vessels specified in the European Union’s (EU) 16th sanctions package, are already likely to be refused entry to European and American ports. But, in non-European countries, port state control presents an opportunity to control the flow of vessel traffic more tightly while also serving important environmental goals. While the international regulations enforced by other regional MOUs are largely consistent with those enforced in Europe, the rigour of a standard ship inspection – and the systems in place to determine which vessels should be inspected at all – are often much worse. For example, Montenegro only joined the Paris MOU in 2023, but for a decade prior it was an associate member, so in theory operated according to the same standards. Still, interviews with actors on the ground indicate that the quality of inspectors was poor and that the country largely lacked the ability or willingness to monitor compliance rigorously.
Consequently, by working with partner nations abroad to improve their port state control practices, Europe can safeguard the environment while also making it harder for low-quality, sanctions-busting vessels to access friendly ports. The odds of catching sanctions-busting vessels in the act and detaining them for noncompliance are low – the total fleet operating ‘outside the official shipping system’ is maybe a few thousand ships at most, while the People’s Republic of China (PRC) alone saw more than 9,000 port calls just from oil tankers in 2023. But, working with allies and partners, especially in Asia, to strengthen their port state control functions will help to close off ports of call to bad actors by increasing the risk that their ships might be detained, as well as prevented from leaving if they do attempt to enter.
Strengthening port state control should be attractive to allies and partners too. Firstly, it directly addresses environmental risks which could otherwise saddle them with costly cleanups. Secondly, for maritime nations such as the Philippines, which have a larger number of citizens employed as sailors on foreign-flagged vessels, better port state control can help to deliver improved working conditions for their nationals. But efforts to strengthen port state control with partner countries will have to be cognisant of the onshore commercial interests they are likely to affect. In general, more valuable cargoes travel on higher-quality ships. For petroleum products traded in normal, non-sanctioned markets, oil majors’ own internal vetting standards are likely to be more stringent than what even enhanced port state control would achieve in most Asian ports. However, low-margin industries such as lumber or scrap metal, or illicit commerce such as trade in sanctioned oil, depend on access to the cheapest possible vessels, which means that the vessels relied upon are disproportionately likely to be low-quality. As a result, improving port state control standards could threaten specific industries and create targeted costs.
Improving port state control is not a panacea. If a country is open to buying sanctioned Russian oil, then they are unlikely to be very interested in strengthening port state control. But the technocratic nature of port state control means that it can be addressed with less politicisation. And implementing countries see clear benefits too in reducing their exposure to environmental risks. Furthermore, it reduces the number of ports where the shadow fleet can safely call, which makes life more difficult for these vessels and slightly easier for the analysts who track them. With the shadow fleet growing in response to sanctions from free and open nations, there has never been a better time to strengthen port state control globally. Multiple collisions with likely shadow fleet vessels have already occurred. Thankfully, none of these accidents have caused large-scale environmental damage, but the world will not always be this lucky.
Eoin Lazaridis Power is a Senior Associate at Arnovia, a boutique provider of transaction advisory services in the aerospace and defence sector. He holds a PhD in Political Science from the University of Texas at Austin; an MA in Russian, East European and Eurasian Studies from the University of Michigan; and a BA in Political Science and Philosophy from Middlebury College.
Fieldwork supporting this article was funded by American Councils’ US Department of State Title VIII Research Scholar Programme.
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