Tracing the Shadow Fleet: What EGRUL Ownership Chains Reveal About the Companies Moving Sanctioned Oil

The registry that cannot see the ship

There is a version of this story that writes itself: pull the EGRUL extract, follow the participant lines upward, and arrive at the owner of a tanker carrying sanctioned crude. That version is wrong, and the error is instructive. EGRUL — the Unified State Register of Legal Entities maintained by the Federal Tax Service — is a registry of Russian legal entities. It records who registered a company, where it sits, who directs it, and what business purpose it declared. It does not record ships. It does not record foreign parents. It does not record beneficial owners beyond the first Russian layer. A vessel is not a legal entity, and a legal entity is not a hull.

What EGRUL can do is narrower and more useful than the fantasy: it can establish the Russian middle of an ownership chain — the manager, the management company, the registration history — and it can show where that chain exits the registry’s jurisdiction. For the two tankers documented in the Ukrainian government’s shadow-fleet database, BRATSK (IMO 9411020) and PROSPERITY (IMO 9322956), the Russian segment is visible and specific. The rest of the chain is not, and pretending otherwise is how analysis of this subject goes wrong.

What the sanctions record actually says

The Ukrainian shadow-fleet entries are explicit about the structure. For BRATSK, the entry states that the tanker is “affiliated through related companies with the sanctioned PJSC Sovcomflot” and that it “is managed by Invest Fleet LLC, a russian company established in December 2023.” The same entry adds: “Invest Fleet LLC is managed by the russian LLC SCF Arctica, a subsidiary of the sanctioned PJSC Sovcomflot.” That is a three-step chain — Sovcomflot, SCF Arctica, Invest Fleet — with the vessel at the end of it.

For PROSPERITY, the entry names New Fleet Ltd as ship owner, commercial manager and safety management manager, all dated 28.05.2025. The vessel’s former name was NS Pride, and its former flags were Liberia, Gabon and Barbados. BRATSK’s former name was NS Burgas, with former flags Liberia and Gabon.

These are attributed findings, not registry facts. The Ukrainian database is a sanctions authority’s assessment, and it should be read as such. But it is specific enough to be checked against Russian corporate records, and that is the point of this exercise: not to accept the chain, but to see which links a Russian registry extract can independently confirm and which it cannot.

The Russian segment: what an EGRUL extract can show

For Invest Fleet LLC and New Fleet Ltd, a standard EGRUL extract returns a defined set of fields: full and short name, INN and OGRN, registration date, registered address, OKVED activity codes, the general director, and the participants (учредители) with their share sizes. Where the participant is itself a legal entity, the extract names that entity and its INN. Where management is delegated to a management company (управляющая компания), the extract records that too.

This is where the registry does real work. If Invest Fleet LLC’s extract names LLC SCF Arctica (INN 1117847157086) as its management company or participant, the Sovcomflot link moves from a sanctions authority’s assertion to a documented Russian corporate relationship. That is a meaningful upgrade in evidentiary status — not proof of vessel ownership, but proof of who controls the managing entity.

The registry also records time. Invest Fleet LLC was established in December 2023, according to the sanctions entry. New Fleet Ltd appears in the PROSPERITY record with a 28.05.2025 date. Those dates matter because they sit against the sanctions calendar: the US designated Sovcomflot-linked vessels in early 2024, the UK in November 2024, the EU in February 2025. A manager incorporated in December 2023 and another appearing in mid-2025 are consistent with the pattern the sanctions entry describes — vessels moved to newly created Russian entities as designations accumulated. The registry cannot prove motive. It can prove sequence.

Where the chain leaves the registry

The critical sentence in the Ukrainian entry is this: “After the sanctions were imposed, PJSC Sovcomflot transferred dozens of vessels to the ownership of companies it had set up, including in foreign jurisdictions, and began the practice of constantly ‘juggling’ (transferring) vessels to related companies.”

Read that carefully. The companies were set up including in foreign jurisdictions. EGRUL stops at the Russian border. If a vessel’s registered owner is a Dubai or Hong Kong or Seychelles entity, no Russian registry extract will show it, and no chain of Russian participants will reach it. The Russian manager — Invest Fleet, New Fleet — is the visible middle of the chain, not its origin and not its terminus. The beneficial owner may sit above a foreign holding company that EGRUL has never heard of.

This is the structural gap that the “EGRUL ownership chain” framing obscures. The registry is strongest exactly where the sanctions record is thinnest — the Russian management layer — and weakest exactly where the vessel title sits. An analyst who treats the EGRUL extract as the whole chain will systematically overstate what Russian records establish and understate the foreign layer that the sanctions authorities are actually targeting.

The identity problem: names are attributes, not keys

BRATSK was NS Burgas. PROSPERITY was NS Pride. Both carried Liberian and Gabonese flags before their current Russian registration; PROSPERITY also flew the Barbados flag. This is not incidental detail. It is the reason name-based matching fails.

If you search EGRUL or SPARK for a company name associated with “NS Burgas,” you will find nothing, because the vessel’s name changed and the owning entity may never have carried the vessel’s name at all. If you match on the current name, you will miss the prior corporate history. The only stable join key is the IMO number — 9411020 for BRATSK, 9322956 for PROSPERITY — because the hull keeps its number when the name and flag change. Vessel names and flags should be treated as dated attributes: valid from a date, superseded on a date. A dataset that stores “BRATSK” as a fixed identifier will silently corrupt every historical join.

The same discipline applies to corporate entities. Russian companies change addresses, directors, OKVED codes and participants. An EGRUL extract is a snapshot with a date, not a permanent description. Where the sanctions record gives a date — 28.05.2025 for New Fleet’s role on PROSPERITY — the registry extract should be pulled as close to that date as possible, or the change history should be reconstructed from the registration authority’s records. Comparing a 2026 extract to a 2024 sanctions designation and calling the difference a discrepancy is a common and avoidable error.

What the open-data catalogue adds — and what it does not

The Federal Tax Service publishes machine-readable open data under an open licence that permits reproduction, redistribution and commercial use. The catalogue is relevant here for two dataset families. First, the address datasets: the service publishes a list of addresses registered as the location of several legal entities, which is the standard tool for identifying shared-address clusters — the mass-registration addresses that often sit behind shell structures. Second, the person-level datasets: the catalogue includes data on individuals who are founders or participants of several legal entities, and on individuals who are heads of several legal entities. These are the datasets that let an analyst move from a single company to a network without manually opening hundreds of extracts.

What the catalogue does not contain is a vessel registry, a beneficial-ownership register, or a foreign-company register. The open data is a Russian entity graph. It is powerful within that boundary and silent outside it. The licence terms are permissive; the coverage is not universal. Confusing the two is the most common methodological failure in this literature.

Reading the sequence against the sanctions calendar

The dates in the two vessel records are worth laying out plainly, because the pattern is the argument.

BRATSK: the sanctions entry records US designation in February 2024, UK designation on 25 November 2024, EU designation on 24 February 2025 (in force 25 February), Swiss designation on 4 March 2025, Canadian on 21 February 2025, New Zealand on 19 June 2025, Ukrainian on 13 December 2025, Australian on 24 February 2026. The vessel’s manager, Invest Fleet LLC, was established in December 2023 — before the first designation, which is consistent with a pre-positioning move rather than a reaction to it.

PROSPERITY: US designation on 10 January 2025, UK on 24 February 2025, EU from 25 February 2025 (amended 18 July 2025), Swiss on 4 March 2025, Canadian and Australian in June 2025, New Zealand from 12 September 2025, Ukrainian from 13 December 2025. New Fleet Ltd appears as owner and manager with a 28.05.2025 date — after the first wave of designations on this hull.

Two different sequences. One manager incorporated before designation, one appearing after. Both are consistent with the “juggling” pattern the sanctions entry describes, but neither proves it. The registry establishes the incorporation and role dates; the sanctions record establishes the designations; the inference that the timing reflects sanctions avoidance is an interpretation, and it should be labeled as one. What can be said without hedging is that the Russian management layer is dated, documented, and checkable — and that the foreign ownership layer above it is not.

What a court record can add that a registry cannot

EGRUL records registration. It does not record operations. For that, the arbitration case database (kad.arbitr.ru) and the general-jurisdiction database (sudact.ru) are the next instrument. Charter disputes, insurance claims, crew wage cases and tax assessments can surface facts that no registry field contains: which entity actually paid the crew, which entity held the charter, which insurer declined cover, which port agent was owed money.

The methodological caution is the same as with the registry. Case text names parties as they were at filing, and a vessel may appear under a name that has since changed. Search by INN where the case involves a Russian entity, and by IMO number where the case text mentions the hull. A case filed in 2024 against “New Fleet Ltd” and a registry extract pulled in 2026 describe the same entity at different moments; the case may predate a change of director or address that the extract now shows. Date every document.

Court records are also uneven. Many cases settle or are heard in closed session; the published text may omit the commercial detail that matters. The absence of a case is not evidence of clean operation. It is evidence of nothing.

What this means for the “shadow fleet” question

The honest conclusion is structural. Russian corporate records can establish, with a date and a document number, that a named Russian entity manages a named tanker, and that the manager is linked to a named parent. They can establish when that entity was created and when its role began. They cannot establish who ultimately owns the vessel, because the ownership layer is foreign and the registry is national. They cannot establish the cargo, because cargo is not a corporate fact. They cannot establish the beneficial owner behind a foreign holding company, because EGRUL has no jurisdiction over it.

This is not a reason to abandon the registry. It is a reason to use it for what it does. The Russian manager is the point of contact between the sanctioned system and the Russian legal order — the entity that can be named, dated, and checked. The foreign owner is the point the sanctions authorities are actually chasing, and it is visible in their designations, not in the tax service’s extracts. An analysis that keeps those two evidentiary domains separate will be more useful than one that merges them into a single confident chain.

The shadow fleet is not hidden because the records are secret. It is hidden because the records are split across jurisdictions, and each jurisdiction’s registry answers only its own question. The work is in the join, and the join is where the honesty has to be.

Sources and Methods

Primary sources consulted for this analysis.

• Ukrainian government shadow-fleet database, vessel entry for BRATSK (IMO 9411020), war-sanctions.gur.gov.ua/en/transport/shadow-fleet/159. Used for: the Sovcomflot affiliation statement, the Invest Fleet LLC and SCF Arctica management chain, the December 2023 incorporation date, former name NS Burgas, former flags Liberia and Gabon, and the designation dates by jurisdiction.
• Ukrainian government shadow-fleet database, vessel entry for PROSPERITY (IMO 9322956), war-sanctions.gur.gov.ua/en/transport/shadow-fleet/688. Used for: New Fleet Ltd as owner and manager dated 28.05.2025, former name NS Pride, former flags Liberia, Gabon and Barbados, the statement on Sovcomflot’s transfer of vessels to companies including in foreign jurisdictions, and the designation dates.
• Federal Tax Service of Russia, open-data catalogue, nalog.gov.ru/opendata/. Used for: the open licence permitting reproduction, redistribution and commercial use; the dataset of addresses registered as the location of several legal entities; the datasets on individuals who are founders or participants of several legal entities and on individuals who are heads of several legal entities.

Registry fields to pull for each named Russian entity. Full and short name; INN; OGRN; date of registration; registered address and its change history; OKVED codes and any amendments; general director and dates of appointment; participants with share sizes and their INNs; management company, if any, with its INN; and the date the extract was generated. Pull the extract as close as possible to the sanctions-record date being tested, and record the generation date alongside every field.

Join keys. Vessel identity: IMO number, treated as the primary key; vessel name and flag stored as dated attributes with valid-from and valid-to fields. Entity identity: INN, not name, because names change and transliterations vary. Where a case record or sanctions entry gives only a name, resolve to INN before joining.

What each source can and cannot verify. The sanctions database can verify that a designation exists and what the designating authority asserts; it cannot independently verify the underlying ownership. EGRUL can verify Russian registration facts as of the extract date; it cannot verify foreign ownership, vessel title, cargo, or beneficial ownership. Court records can verify that a dispute was filed and what the published text states; they cannot verify the absence of undisclosed arrangements. The open-data catalogue can verify that a dataset exists and its licence terms; it cannot verify that a given entity appears in it without a query.

Known gaps in this analysis. No EGRUL or SPARK extract for Invest Fleet LLC (INN 1237800143569), New Fleet Ltd (INN 1237800143866) or LLC SCF Arctica (INN 1117847157086) was retrieved for this piece; the participant and management-company links rest on the sanctions authority’s description and should be confirmed against a dated extract before being treated as registry-verified. No primary sanctions instrument (US Treasury, UK, EU, Canada, Switzerland, New Zealand, Australia, Ukraine) was retrieved to replace the aggregator’s summary of designation dates. No IMO GISIS or equivalent vessel record was retrieved to confirm flag history independently. These are the next documents to pull, and the conclusions above are drawn to survive their arrival: the structural point — that EGRUL covers the Russian middle of the chain and not its foreign ends — does not depend on any single extract.