By: Ayoola B. Fadola, a Senior Legal Officer of the Nigerian Shippers’ Council
The peaceful waters of The Gambia initially appear to be an improbable setting for global maritime intrigue. A troubling reality lies beneath this serene surface, with numerous oil tankers of mysterious origin flying the Gambian flag. The notorious “dark fleet” connections turned The Gambia’s maritime registry into an appealing destination for ships performing questionable activities. The Gambia has seen a dramatic increase in oil tanker registrations from the notorious “dark fleet,” which operates in secrecy and often participates in sanctioned trades. This raises concerns about maritime safety and the nation’s reputation as a responsible flag state.
In just two years, The Gambia’s maritime registry has undergone a dramatic transformation: The number of tankers flying The Gambia’s flag increased from zero in 2023 to 35 oil and gas tankers by March 2025. The rapid expansion of fleet capacity, from 26,665 deadweight tons (dwt) in 2023 to more than 3.6 million dwt by March 2025, resulted mainly from the introduction of “dark fleet” vessels engaged in sanctioned oil and gas trades with concealed ownership structures.
An overwhelming 99% of these tankers, by tonnage, face US, UK, or EU sanctions or participate in sanctioned trade operations, prompting serious concerns regarding maritime safety and regulatory control, as well as The Gambia’s involvement in the global shadow shipping network. The rising number of Gambian-flagged ships detained in overseas ports has prompted the country to discuss the dangers and duties this new shipping landscape presents.
This article examines the growing number of “dark fleet” vessels under The Gambia’s flag, while also investigating their maritime safety and environmental implications, as well as their impact on The Gambia’s international standing and regulatory obligations. By discussing these challenges, the article aims to educate readers and policymakers about the importance of increased oversight and transparency in ensuring maritime safety and adherence to global standards.
The increase in Western sanctions against Russia, Iran, and Venezuela has led to a surge in covert hydrocarbon transportation conducted by tankers using flags of convenience from open registries with weak flag state control and inadequate port state compliance to hide beneficial ownership and evade regulatory enforcement which this practice is known as the “dark fleet.” Since 2023, The Gambia’s previously minor and low-activity international ship registry has witnessed a dramatic rise in crude oil and product tanker registrations, including vessels associated with sanctioned trade flows. These units frequently execute ship-to-ship (STS) petroleum cargo transfers in extraterritorial waters to mask cargo provenance, systematically deactivate Automatic Identification System (AIS) transponders to elude long-range identification and tracking protocols (“going dark”), and engage in serial reflagging to exploit regulatory arbitrage and obscure ultimate beneficial ownership. This registry expansion has precipitated heightened international scrutiny, positioning The Gambia as an emergent flag of convenience jurisdiction for high-risk tonnage facilitating sanctions evasion, with concomitant ramifications for global maritime security, marine environmental protection, and the reputational integrity of the Gambian Maritime Administration.
Tanker owners use the Gambian flag due to regulatory pressures, economic opportunities, and geopolitical dynamics created through the interaction between international and national maritime organizations. Tanker operators seeking to bypass Western sanctions and stringent compliance rules are turning to registries that offer minimal flag state enforcement, alongside less extensive due diligence checks and expedited provisional registration services. To grow registry revenues and international tonnage, the Gambia’s Maritime Administration (GMA) implemented a liberal registration system that depends on third-party organizations for vessel vetting and documentation.
NS Union remains the only Gambia-flagged vessel not stopped by port state inspectors. Source: Lloyd’s List Intelligence / Seasearcher
The increased registration of tankers in The Gambia’s registry demonstrates a calculated move by shipowners looking for jurisdictions with more lenient regulations. There are several reasons, but the two main practices weakening international maritime oversight are provisional registration and flag-hopping. These mechanisms undermine maritime oversight by allowing vessels to adopt new flags and operate with minimal inspection, despite involvement in blacklisted oil trades or past violations.
The Gambia allows ships to remain provisionally registered for three months (extendable for an additional three months) while authorities conduct due diligence. Shipowners take advantage of this window to preserve temporary legitimacy and avoid examination. The tanker Anita, for instance, operated under temporary registration in Gambia following its expulsion from Sudan and Cameroon while conducting Iranian oil trades. The Gambia permits ships to operate under its flag when they apply for provisional registration, provided that they have not undergone complete safety inspections, ship checks, or sanction screenings. The fast-tracked registration process, created to attract foreign shipping business, has transformed into a significant loophole that vessel operators exploit to bypass stricter regulatory standards.
The Gambia ship registry is managed by MDIR Services Ltd, based in Cyprus, which faces accusations of prioritizing commercial interests over regulatory responsibilities. The outsourcing of registry management leads to verification gaps for vessel ownership and operational history, which permit sanctioned ships such as Gas Leader to register. The Gambia Maritime Administration (GMA) stated that provisional registration allows ships to operate before technical survey completion based on the ship owners’ self-declarations.
Data obtained from Lloyd’s List demonstrates that numerous tankers that have received new registrations under the Gambia flag previously operated under other flags and changed their registrations around the time of dubious oil trading activities. The tanker ASTERIX (IMO 9181194) was registered with the Gambia before it faced U.S. sanctions, which demonstrates how ships use this route to hide their operating backgrounds.
Oil tankers involved in sanctioned trades utilize the Gambia as a strategic haven while engaging in flag-hopping to conceal vessel ownership and evade enforcement by rapidly changing registries. During 2025, ships switched registry to The Gambia within an average of 45 days following sanctions, showing a significant increase in reflagging speed compared to earlier years. The Sands tanker received a U.S. designation for supporting Houthi activities and was promptly reflagged to The Gambia following its expulsion from the Cook Islands registry. The nation attracts ships because it has minimal regulatory control and accepts vessels rejected by other flags.
The fact that The Gambia operates as a flag of convenience highlights critical flaws in international maritime regulation driven by the unclear “genuine link” provision of Article 91 in UNCLOS. The 1986 UN Convention sought to strengthen the registration of ships by improving transparency and accountability standards. Still, it failed to become an active law, supporting states like the Gambia in maintaining loosely regulated ship registries. The Gambia maintains its registry operations without ratifying the convention, which enables it to attract foreign-owned vessels without meaningful regulatory oversight and creates opportunities for obscure ownership structures and practices, such as flag-hopping and sanctions evasion. Anonymous vessel owners can register ships through shell companies without establishing genuine operational or economic relationships with the country. Sanctioned fleets, especially those connected to Iranian and Russian interests, have been able to operate globally with minimal supervision, which continues to damage the international shipping system’s reputation.
Examples of detention due to safety/environmental violations
Gas Leader (IMO 9114581): The ship was detained in Humen, China, because of non-functioning lifeboats, failures in ballast water management, and incomplete fire protection systems. The vessel failed to meet the requirements of SOLAS Chapter II-2, which covers fire safety measures, and MARPOL Annex I, which focuses on oil pollution prevention, specifically Rule 6.
Anita (IMO 9203253): Chinese authorities detained the 157,831-ton oil tanker Anita in Rizhao because it had issues with watertight integrity and structural fire safety violations while failing to comply with ISM Code standards. The vessel received provisional registration from The Gambia in November 2024 but remained operational under that flag despite persistent defects 6.
Katsuya (IMO 9178068): The Dongjiakou authorities detained the ship due to incorrect certificates and multiple violations under MARPOL Annex VI, relating to air pollution and fire safety issues. The vessel received permission to proceed after implementing corrective measures 6.
Salakh 22 (IMO 1108122): The vessel remained detained in Taizhou for close to two weeks because of its defective rudder angle indicator and missing tonnage certificates. The lack of a classification society worsened this vessel’s compliance issues.
Environmental Risks to Marine Ecosystems
Pollution incidents involving vessels registered under the Gambian flag pose risks to marine biodiversity. The Anita tanker faced detention due to improper handling of ballast water and oil leakage, which could introduce invasive species and toxic materials into vulnerable marine zones. Ships such as the Katsuya violated MARPOL Annex VI standards through their air pollution practices, resulting in increased greenhouse gas emissions and ocean acidification. The dark fleet remains unconnected to The Gambia’s coastal waters, which continue to endure further ecological strain from illegal industrial fishing activities that utilize undersized nets, harming habitats and producing excessive bycatch, ultimately leading to environmental disruption.
Seafarer Welfare and Safety Concerns
Seafarers aboard certain Gambian-flagged ships face concerns due to working conditions that reveal substantial safety problems. The Gas Leader, for instance, failed to meet mandatory SOLAS Chapter III standards for essential life-saving equipment and fire safety measures. These breaches create life-threatening conditions for crews.
Gaps in International Maritime Law Compliance
The detentions of ships under the Gambian flag for safety and pollution issues expose serious non-compliance with major international standards. The Anita and Gas Leader demonstrated breaches in watertight integrity and fire protection, contravening SOLAS Chapters II-1 and II-2. MARPOL violations through unmanaged ballast water and oil discharge reveal persistent non-compliance issues. Although the Gambia Port Authority mandates compliance with MARPOL standards, its enforcement mechanisms are ineffective, as evidenced by the continuous occurrence of regulatory breaches. Flags of convenience ship registries that fail to implement the International Maritime Organization’s 2023 SOLAS/MARPOL joint fuel sampling guidelines weaken these initiatives.
Systemic Challenges and Regulatory Loopholes
Gambia’s flagging system faces a significant threat from its temporary registration procedure. The Anita and similar ships exploit this loophole to commence operations before completing their safety checks, thereby disregarding SOLAS and MARPOL regulations. The persistent detection of flaws alongside repeated ship detentions demonstrates deficient audit procedures and insufficient oversight mechanisms.
The Gambia Maritime Administration typically categorizes ship detentions as either politically driven or routine checks. Still, the severe deficiencies, including non-functional lifeboats and missing documentation, reveal underlying systemic issues that endanger marine environmental quality and human safety.
International Implications of The Gambia’s Maritime Practices
The Gambia Maritime Administration faces significant challenges due to its rapidly growing ship registry, which has attracted extensive scrutiny and criticism. Lloyd’s List and The Gambia Journal reported that multiple Gambian-flagged ships, including oil tanker vessels, were detained in Chinese ports because of safety and environmental infractions; some had connections to sanctioned oil trades. The GMA dismissed allegations about its ship registry as a “coordinated campaign,” yet its responses have not quelled doubts regarding The Gambia’s compliance with international maritime norms. The rapid increase in Gambian registry vessels from five ships in 2023 to thirty-five tankers by 2025, many of which are allegedly tied to sanctioned entities, has amplified concerns that The Gambia functions as a “flag of convenience” for high-risk shipowners, which damages its maritime reputation.
The decrease in reputation affects the worldwide enforcement of sanctions. According to analysts, more than 99% of new Gambian tanker registrations engage in oil trade with sanctioned nations, including Iran, Russia, and Venezuela. Lax registration standards and insufficient due diligence practices have encouraged extensive “flag-hopping,” enabling ships to avoid scrutiny through flag switching. The delegation of registry functions to Cyprus-based MDIR Services Ltd. through its subsidiary Gambia International Ship Registry (GISR) has generated major concerns regarding effective oversight and transparency. The absence of proper regulatory controls permits sanctioned ships to function without detection, creating significant challenges for worldwide maritime sanction enforcement.
International responses reflect growing unease. The GMA asserts alignment with international maritime standards and participation in the Abuja MoU, but ongoing detentions of Gambian ships indicate enforcement failures. The government faces criticism from environmental and human rights organizations, including Amnesty International and the Gambia Environmental Alliance (GEA), which collaborate with Greenpeace Africa, for its poor oversight of illegal fishing and environmental harm caused by foreign industrial fishing operations. Although not officially recorded, the increasing number of sanctioned tankers flying the Gambia’s flag will likely lead to heightened oversight from Western authorities, such as the U.S. Treasury’s Office of Foreign Assets Control (OFAC), which could result in sanctions against the nation unless preventive measures are implemented.
Recommendation & Conclusion
The persistent safety and environmental deficiencies of Gambian-flagged ships, combined with the registry’s susceptibility to flag-hopping and temporary gaps, create severe threats to marine environments and seafarer safety. The repeated detention of vessels such as ANITA, GAS LEADER, and KATSUYA due to major infractions highlights systemic issues within maritime operations that fail to meet the requirements established by international maritime regulations, including SOLAS and MARPOL. These deficiencies have widespread negative impacts, resulting in higher pollution levels and the proliferation of invasive species, while endangering ship crews working under inadequate and hazardous conditions.
The central issue stems from a registry system that has prioritized rapid fleet growth and commercial gain over intense supervision and strict adherence to rules. The dependency on provisional registrations and external management creates insufficient due diligence, allowing vessels with suspect backgrounds to function without consequences. The questionable practices damage the reputation of the Gambian flag while weakening confidence in international maritime regulations.
A multifaceted strategy is necessary to break the pattern of non-compliance while rebuilding trust in the Gambian registry. First, regulatory oversight must improve by funding internal expertise resources and decreasing dependency on external management services. Establishing more rigorous vetting procedures throughout both provisional and permanent registration processes would secure the compliance of vessels flying the Gambian flag with international safety and environmental requirements. Unannounced inspections conducted regularly at ports and onboard ships would discourage substandard operations while helping authorities identify potential violations early.
Enhancing transparency in vessel ownership and management operations will eliminate the opportunities that allow entities to bypass sanctions and avoid oversight. Collaborating with international organizations such as the IMO and regional port state controls will enhance both information sharing and enforcement capabilities. The Gambia can safeguard its reputation and support global shipping safety and environmental protection initiatives by implementing these reforms and demonstrating a commitment to maritime safety and environmental stewardship. Political determination and practical measures will resolve this “brouhaha,” providing significant benefits to seafarers and the environment while preserving global trade integrity.
