그림자선단과 관련된 해상법적 쟁점 검토

The recent expansion of the so-called “Shadow Fleet” or “Dark Fleet” – an informal maritime network of ageing tankers that transport Russian, Iranian, and Venezuelan crude oil in circumvention of international sanctions – poses serious challenges to global maritime governance. These vessels often exploit flags of convenience, manipulate Automatic Identification Systems, engage in repeated ship-to-ship transfers on the high seas, and in some cases sail without valid insurance. As a result, they threaten not only maritime safety and environmental protection but also the stability of global supply chains. The issue goes beyond mere sanctions evasion. Although international regimes led by the United Nations Security Council, the U.S. Office of Foreign Assets Control, and the European Union/United Kingdom have established sanctions frameworks, their enforcement remains fragmented and incomplete. Individual companies also struggle to cope. Shipping lines and logistics firms face heightened risks in vessel disposal, counter-party transactions, and cost volatility in freight and insurance markets. To mitigate such risks, firms must move beyond basic due diligence, employing transparent digital platforms and strengthening ESG and supply chain disclosures. Likewise, insurers and financial institutions confront intricate compliance challenges. P&I Clubs, reinsurers, and banks, sanction risks are deeply entangled, while reliance on Blue Cards issuance or self-attestation has revealed significant shortcomings. The Shadow Fleet, therefore, represents a multifaceted problem that cannot be reduced to the responsibility of a single actor. National regulation and corporate compliance are mutually dependent but remain misaligned. What is required is a comprehensive response involving shipping companies, insurers, financial institutions, logistics providers, and governments alike. In this background, this study examines the legal and practical implications of the Shadow Fleet for the international maritime law. Whereas existing research has primarily focused on the international legal justification and effects of economic sanctions or the prospects of public regulation of the Shadow Fleet this article reframes the issue from the perspective of private actors. Specifically, it analyzes how sanction risks affect vessel disposal, marine insurance and reinsurance markets, financial compliance systems, and supply chain management of Korean logistics firms. On this basis, it proposes practical response strategies for shipping and logistics companies, insurers, and financial institutions. By highlighting the intersection between international sanctions and corporate risk management, this study contributes to both legal scholarship and policy discussions on maritime governance and sanctions compliance.