# Shadow Fleets: A Growing Challenge in Global
## 3 Dark Fleets and Gray Fleets: A Comparative Analysis
### Gray Fleet: Operational Modalities  
The gray fleet represents a more nuanced phenomenon in the landscape of shadow maritime operations, characterized by its operation in a zone of legal ambiguity. Unlike dark fleets, gray fleet vessels typically maintain active Automatic Identification System (AIS) transmitters, although data manipulation is not uncommon [12]. This practice of maintaining active AISs while potentially altering the transmitted data allows these vessels to project an appearance of compliance with international maritime regulations while still obscuring aspects of their operations.  
A defining feature of the gray fleet is its exploitation of regulatory loopholes and jurisdictional complexities, an approach that bears striking similarities to the concept of gray zone warfare in international relations. Gray zone warfare refers to actions that fall between the traditional binary of war and peace, often involving covert or deniable operations that exploit ambiguities in international law and norms [13]. In a similar vein, gray fleet vessels operate in a gray area of international maritime law, leveraging the intricacies and inconsistencies in global maritime regulations to their advantage. This strategic approach allows them to navigate the complex web of international sanctions and trade restrictions while maintaining a veneer of legitimacy. Much like state actors engaging in gray zone tactics, gray fleets employ various methods to project an image of compliance, carefully managing their visible operations to appear adherent to international norms while obscuring their true operational nature. This parallel underscores the sophisticated nature of gray fleet operations and highlights the challenges they pose to traditional regulatory and enforcement mechanisms in the maritime domain.  
The emergence of the gray fleet as a significant actor in global maritime trade is particularly evident in its role in the transportation of Russian oil. Comprising over 900 vessels, this fleet has become instrumental in facilitating oil exports to non-sanctioning countries, including China, Turkey, and India [14]. The composition of the gray fleet reflects its specialized role in this trade, with a significant proportion dedicated to oil transportation: 33% are crude oil tankers, 23% are oil product tankers, and 20% are oil/chemical tankers. This specialized fleet structure underscores the gray fleet's strategic importance in circumventing international sanctions on Russian oil exports.  
The operational patterns of gray fleet vessels are notably demonstrated by the ADVANTAGE ANGEL (IMO: 9779953), registered under the Marshall Islands flag. This vessel exemplifies the nuanced approach characteristic of gray fleet operations, maintaining formal registration and selective AIS compliance while engaging in sanctioned trade routes. Documentation reveals the transport of 500,000 barrels of crude oil along contentious routes, yet the vessel maintains its formal flag registration and corporate structure, illustrating the gray fleet's strategy of operating within technical compliance while pursuing questionable activities.  
Similarly, the STI DUCHESSA (IMO: 9669938), also registered in the Marshall Islands, demonstrates the sophisticated methods employed by gray fleet operators to maintain a facade of legitimacy while facilitating sanctions evasion. The vessel's operations involve the transportation of refined products of Russian origin through complex indirect routes, utilizing transshipment points in India before they reach their final destinations. Whilemaintaining active insurance and registration, the vessel's operations reveal the intricate mechanisms through which gray fleet operators exploit regulatory ambiguities.