Ministers from the Council of the Baltic Sea States discussed regional security and the activities of Russia's shadow fleet, hundreds of old ships Moscow uses to transport goods and oil, at the Ministerial Session 2025 on Friday morning in Estonia.

The incident this week, where a Russian fighter jet violated Estonia's airspace to protect a tanker, was also raised.

The Estonian authorities initially tried to stop the "Jaguar" tanker after they suspected it was sailing without a flag, which is illegal under international law. This is not the first such incident Estonia has dealt with.

"What I have learned today, I am actually shocked by," Sikorski, said at a press conference following the meeting in response to a question from ERR. "I've known there are these flags of convenience – that are the functional equivalent in the maritime sphere of tax havens in the financial sphere – but it's worse. There are apparently ships that ply the waters that have no flag at all!"

He continued: "So the question is, who is responsible when something bad happens? What if someone loads up a ship with radioactive material and something happens? What if there is a large spill of oil in a shallow sea like the Baltic Sea? Who will then be responsible for cleaning up the damage?"

Under international law, when a state grants a ship the right to sail under its flag, it takes legal responsibility for the vessel.

Sikorski said "urgent action" needs to be taken.

Speaking about what more can be done to stop the shadow fleet, Sikorski said: "As a last resort, we have the right of self-defense – but that's a blunt instrument. We need a better regulation that creates a predictable and safe environment for international trade and navies to operate in."

Estonia's Minister of Foreign Affairs Margus Tsahkna mentioned a comparison by German Minister of State for Europe Gunther Krichbaum, who also attended Friday's meeting, with aircraft.

"We cannot imagine that we have a plane which is having no owner or flag that can just cross our territories, he said. "The shadow fleet is the same thing. We need to change our mentality."  

Unknown cargo

Speaking about the "Jaguar" case, Tsahkna (Eesti 200) said there were several firsts from Russia.

"What was totally new was that for the first time ever, Russia sent a fighter jet and also violated the NATO airspace /../ this is the first time that Russia used military power to fight against the economic sanctions that we have put on the shadow fleet. This is a new level of involvement, and we need to take it very seriously," he said.

"This was the first time that Russia actually linked – officially we can say – [itself] to shadow fleet issues. Before that, it was something without flags, without ownership. The vessels they came and went, but now this is very high-level and understandable that Russia is connected."

There are also suspicions that the tanker may have been transporting something other than oil.

"The jet was not only escorting this vessel during the Estonian Economic waters but actually to St Petersburg," he said. "We don't know exactly what this vessel was carrying, maybe something very important for Russia."

The CBSS is an intergovernmental organisation that unites 10 democratic, like-minded states and the European Union in political dialogue and practical cooperation on key issues in the Baltic Sea Region.

The council was established in 1992 by the foreign ministries of the Baltic Sea Region countries: Denmark, Estonia, Finland, Germany, Iceland, Latvia, Lithuania, Norway, Poland, and Sweden.

Estonia currently holds the rotating presidency and Poland will take over in July.

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