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When sanctions become piracy with a government stamp

By Dan-Viggo BERGTUN – steigan.no – July 29, 2026

Vladimir Putin has recently announced that attacks, harassment, and unlawful interference with Russian commercial shipping will be met in the same manner as piracy. This statement will naturally be portrayed as yet another Russian threat. But before European politicians dismiss it as propaganda, they should consider a far more uncomfortable question: What do we call it when states stop merchant ships, board them, seize cargo, or attempt to determine who is allowed to sail the world’s oceans?

Since 2022, the European Union has built up an increasingly comprehensive sanctions regime against Russia. More and more vessels have been linked to what the EU terms the Russian “shadow fleet.” The ships may be denied access to European ports and face prohibitions on insurance, financing, technical assistance, and other maritime services.

These are serious measures, but it is important to be precise: A European port ban is not the same as a general right to board foreign vessels on the high seas. Nor is there any automatic right to seize cargo from a ship simply because the EU believes the trade violates European sanctions.

But the development is dangerous. The United Kingdom and several European countries are discussing increasingly offensive measures against vessels alleged to be circumventing sanctions. The ships are accused of complex ownership structures, inadequate insurance, false flag registrations, poor technical standards, or concealing cargo and movements. Some of the concerns may be genuine. Old tankers without sufficient insurance can pose a serious risk to the environment and other shipping.

But suspicion is not the same as a conviction.

The EU calls this a “shadow fleet.” Russia rejects the designation. The term is politically effective because it creates the impression that the ships are virtually lawless ghost vessels that any Western navy can intervene against. But a ship that flies a valid flag, has a crew, a registered owner, and sails outside other states’ territorial waters does not automatically lose its rights simply because its cargo is Russian or because the EU disapproves of the trade.

Nor are European countries alone in acting this way. The United States has for several years seized oil that it claims has been transported in violation of U.S. sanctions against Iran. American courts have issued forfeiture orders, and U.S. authorities have taken over, sold, or seized oil from foreign tankers.

As early as 2020, the U.S. Department of Justice announced that the United States had confiscated approximately 1.1 million barrels of Iranian petroleum products from four foreign-flagged tankers. U.S. authorities stated that the seizure was carried out with the assistance of foreign partners. In 2023, over 980,000 barrels of oil from the tanker Suez Rajan were seized and later sold. In 2026, U.S. authorities obtained forfeiture of the tanker Skipper and approximately 1.8 million barrels of oil originating from Iran and Venezuela.

The United States portrays this as legal enforcement of sanctions, counter-terrorism financing efforts, and the forfeiture of illicit cargo. But from the perspective of other countries, it may look quite different: One state uses its own laws and its own courts to take control of other countries’ commercial goods far outside its own territory.

What would the United States say if an Iranian or Chinese court decided to seize American oil en route to Europe? What would Norwegian authorities say if a Norwegian ship were stopped on the high seas because its cargo violated another country’s unilateral sanctions?

We would hardly call that ordinary law enforcement. We would call it theft, abuse of power, or piracy.

It must be emphasized, however, that not all U.S. seizures have occurred through armed hijackings on the high seas. Some have been carried out in cooperation with shipowners, operators, flag states, or foreign authorities. Others have been based on claims that the ship was stateless, used a false flag, or had ties to the U.S. financial system. But this does not change the fundamental problem: The United States is attempting to give its national sanctions effect across large parts of the world.

The law of the sea is built on the principle of freedom of navigation on the high seas. The ship’s flag state has both the right and the duty to exercise control over the vessel. The registration ties the ship to a state that also has the right to protect it under international law.

This does not mean that merchant ships can do whatever they want. Piracy, human trafficking, statelessness, false registration, and other serious offenses may provide grounds for intervention. Coastal states also have extensive authority in their own territorial waters and ports. But economic sanctions adopted by the United States or the EU are not automatically world law.

As a veteran union representative, I myself have met Admiral Aleksandr Moiseyev on veteran affairs. He is now Commander-in-Chief of the Russian Navy. During our meeting, he gave a detailed account of the rescue efforts following the sinking of the nuclear submarine Kursk in the Barents Sea in August 2000. He described the enormous technical challenges, the time pressure, and the human drama surrounding the attempt to reach the crew. All 118 people on board lost their lives.

The conversation made a strong impression on me. It reminded me that the sea is not merely an arena for military power, sanctions, and political posturing. It is also a merciless workplace where even the mightiest navies can be put to the test, and where cooperation between nations can be the difference between life and death.

Norwegian and British experts were eventually brought in to assist with the Kursk operation. This is precisely why it is tragic that the relationship between Norway, Russia, and the rest of Europe is now moving in the opposite direction. Where we once could cooperate on rescue, safety, and human lives in the High North, we now risk encountering each other with warships, boarding parties, and weapons aimed at merchant vessels.

The lessons from the Kursk should have taught us that incidents at sea can quickly escalate into catastrophes. Communication failures, prestige, secrecy, and delayed decisions can cost lives. If European or American forces stop Russian-affiliated merchant ships while Russian naval vessels are ordered to protect them, a single misunderstanding could have consequences no politician has planned for.

This lies at the heart of Putin’s recent warning.

If Western naval vessels attempt to board Russian-affiliated merchant ships, Russia may respond with escort vessels, military presence, or attempts to prevent the boarding. In such a scenario, very little is needed—a warning shot, a navigational error, or a misinterpreted order—to lead to armed confrontation, and even a nuclear conflict.

Thus, we could end up in a situation where nuclear powers face each other around a civilian tanker in the North Sea, the Baltic Sea, the Barents Sea, or the English Channel.

Europe and the United States must ask themselves what principle they are establishing. If Western countries can stop ships because their cargo violates Western sanctions, China could later stop European ships citing Chinese sanctions. Iran could do the same in the Persian Gulf. Russia could draw up its own lists of Western vessels and claim they support hostile activities.

Do we really want a world order where the strongest navy determines what constitutes legal trade?

The conflict in Ukraine can be criticized and condemned without simultaneously tearing down the international legal rules governing global shipping. Sanctions must not become a shortcut to state-sanctioned piracy.

Norway is a maritime nation and should be among the first to demand clarity. The government must clearly state whether Norway will participate in boardings, seizures, or military stops of merchant vessels outside Norwegian territorial waters. It must also explain what international legal basis such intervention would supposedly rest upon.

Because when the great powers grant themselves the right to stop ships, seize oil, and sell the cargo, it is no longer just about sanctions. It is about who has the biggest warships.

When merchant ships become military targets, the path from economic war to actual war has become alarmingly short.

August 9, 2026 Posted by aletho | Economics, War Crimes | European Union, Russia, UK, United States | Comments Off on When sanctions become piracy with a government stamp