# Shadow Fleets: A Growing Challenge in Global
## 3 Dark Fleets and Gray Fleets: A Comparative Analysis
### Dark Fleet: Comparative Analysis of Dark and Gray Fleets  
Despite their nuanced differences, the dark and gray fleets exhibit significant commonalities, especially in their cargo focus, which primarily includes various types of wet cargo. The dark fleet shows a predilection for oil/chemical tankers (35%) and crude oil tankers (32%), whereas the gray fleet prominently features crude oil tankers (33%), oil product tankers (23%), and oil/chemical tankers (20%) [15]. This collective emphasis on transporting wet cargo highlights their pivotal role in the global shipping industry, representing 18% of vessels tasked with such cargo. Ownership structures within both fleets unveil patterns that amplify concerns regarding the evasion of regulations and sanctions. The frequent utilization of flags of convenience from countries like Panama, Liberia, the Marshall Islands, Malta, and Russia is common to both fleets, facilitating their ability to navigate through regulatory loopholes and operate under reduced scrutiny. This strategic choice underscores the challenges in enforcing international maritime regulations and sanctions effectively [16]. Moreover, the age profile of vessels across both fleets introduces serious concerns about safety and environmental risks. Over 50% of vessels in both the dark and gray fleets are 15 years old or older, significantly exceeding the average lifespan of oil tankers. This trend towards an aging fleet, compounded by dubious maintenance standards, heightens the risk of accidents, spills, and consequent environmental hazards [17]. In essence, while the dark and gray fleets may diverge in their operational tactics, they converge in their broader impact on the maritime industry, highlighting issues related to safety, environmental sustainability, and the global effort to enforce sanctions. As shown in Table 1, while these fleets differ in their AIS usage and operational tactics, they share similar characteristics in vessel age and flag choice. Case Study: Chinese Fishing Dark Fleets. The emergence of Chinese distant-water fishing (DWF) fleets during the COVID-19 pandemic illustrates a distinct variant of dark fleet operations. In 2020, a fleet of approximately 340 Chinese vessels operated near the Galapagos Marine Reserve [18], with over 100 vessels regularly disabling their AISs. Unlike Russian oil tankers operating in gray zones of sanctions compliance, these vessels directly violated international fishing regulations while maintaining a facade of legitimacy through partial compliance with tracking requirements [19; 20; 21; 22; 23]. \begin{table}
\begin{tabular}{c c c} \hline
**Characteristic** & **Dark Fleet** & **Gray Fleet** \\ \hline AIS Usage & Often disabled & Typically active, but may be manipulated \\ \hline Cargo Focus & Primarily crude oil and chemicals & Mainly Russian oil \\ \hline Vessel Age & Significant portion over 15 years old & Significant portion over 15 years old \\ \hline Flag Choice & Flags of convenience & Flags of convenience \\  & (e.g., Gabon, Panama, Liberia) & (e.g., Panama, Liberia) \\ \hline Operational Tactics & Complete evasion of detection & Obscuring vessel origins and ownership \\ \hline Estimated Fleet Size & \(\sim\)1100 vessels & \(\sim\)900 vessels \\ \hline Primary Markets & Sanctioned countries & Non-sanctioning countries (e.g., China, Turkey, India) \\ \hline \end{tabular} Source: Own elaboration (compiled from multiple sources).  
\end{table} 
Table 1: Comparative characteristics of dark and gray fleets in maritime operations. Comparative Analysis: EU Fishing Vessels. In contrast to Chinese dark fleets, European Union fishing vessels demonstrate different operational patterns. While maintaining active AISs and formal compliance with regulations, some EU vessels engage in environmentally destructive fishing practices.