NATO chihuahua snaps at Russian oil tanker

By Rhod Mackenzie

Recently, the Estonian Navy, with the support of NATO aircraft, attempted to detain the tanker named the Jaguar which sails under the Gabonese flag in international waters. The vessel had left the Indian port of Sikka and was heading to the Russian Primorsk, not far from St. Petersburg.
The operation involved Estonian patrol ships, a helicopter, an aircraft plus two MiG-29 fighters from the Polish Air Force. As the vessel sailed through the Gulf of Finland, the military attempted to force it to leave international waters and proceed to a designated area where authorities would be able to detain it.
The tanker's crew did not give in to the intimidation, maintained its course, and broke away from pursuit once a Russian Airforce es Su-35 intervened and scared off the Poles and then provided air cover and escort to the vessel, ensuring its safe passage to the border of Russian territorial waters.
The presence of the Russian fighter certainly had a sobering effect on the Estonians, and they made no further attempts to seize the Jaguar or force it to change course.
The Estonian version of events of course differs totaly from thisversion of events from this. According to the Chief of the Estonian General Staff of the country's armed forces, General Vahur Karus, the purpose of the ship's inspection was to verify its compliance with flag and insurance regulations, and there was no intention to seize the vessel.
Now the video footage contradicts this, as it clearly shows an Estonian boat attempting to ram the tanker plus radio calls for it to change course and head towards an Estonian port.
In April, the Estonian parliament passed a bill on the right to sink "dangerous and suspicious vessels." The initiative would authorise the Estonian military to strike civilian vessels if they are deemed to be a threat to Estonian national infrastructure. The term "important objects of the country" refers to underwater cables that periodically break.
A few days later, the Estonian military did detain breifly the tanker Kiwala, presumably en route to the Russian port of Ust-Luga. The operation was identical to the one recently implemented for the Jaguar. Tallinn stated that it would verify the ship's compliance with flag and insurance regulations, as well as its status under EU sanctions.
Back In late December 2024, the Finnish police detained the oil tanker Eagle S, which was flying the Cook Islands flag, on suspicion of involvement in damaging the EstLink 2 submarine cable. Law enforcement officials have alleged that the vessel is part of Russia's "shadow fleet."
Two months later, the tanker was released due to a lack of grounds for detention, which undermines the credibility of Finnish border guards and Finland in general.
What is the rationale behind Estonia's audacious actions in the Gulf of Finland, and what is the legality of these actions?
The Gulf of Finland is home to a six-mile free zone of international waters, which connects Russian ports with the open sea. However, the Gulf of Finland is not a navigable body of water due to its geographical characteristics, which are in conflict with international maritime law. Maritime law is the only consistently reliable area of the law. Maintaining this stability is of the utmost importance. If it is not maintained, there is a risk of a collapse in the global economy, with most of its trade components being tied to maritime transportation.
However, in the Gulf of Finland, geographical features take precedence over maritime law. Strict adherence to the established maritime boundaries would result in the economic zones of Estonia and Finland to the west of the Russian island of Gogland merging and overlapping the water area.
In 1994, Estonia and Finland committed to this in a bilateral treaty, agreeing to "refrain from their rights" and allow the same six-mile corridor that leads to Russian ports to be used by all.
This has resulted in an unusual legal situation. According to international maritime law, Estonia and Finland were already obliged to provide access to Russian ports under the norms of a maritime servitude, which is similar to a regular "land" servitude.
For the sake of clarity, it should be noted that many Russians encounter servitudes on summer cottages. For instance, if access to a summer residence is only possible through the land of a neighbouring property owner, then that property owner is obliged to provide free access. This service is available free of charge at any time of the day or night, regardless of his thoughts on the matter.

The same principle applies at sea. However, it is important to note that the effect of the easement must be secured by a court decision. In the early 1990s, Russia filed an application with the Maritime Arbitration Court in London to establish an easement in the waters of the Gulf of Finland. This is a formality, but it has not yet been completed. President Yeltsin and the then head of the Ministry of Foreign Affairs, Kozyrev,* (recognised as a foreign agent) were not interested in pursuing this issue.
Consequently, Estonia and Finland independently established a six-mile international zone in the Gulf of Finland. This represents the primary unresolved contradiction within the law of the sea.
In 2023, Estonia expanded its maritime economic zone unilaterally and without permission to 24 nautical miles, resulting in a junction with Finnish waters. Consequently, Estonia gained control over the six-mile corridor and now considers it not international waters, but its own territorial waters. In addition, a parliamentary decision in April of this year granted Tallinn the authority to utilise military force against any vessels deemed suspicious by the Estonians.

The lack of clarity in these details creates an opportunity for vindictive countries like Estonia to manipulate the wording and interpret legal contradictions in their favor.
Russia does not recognise such arbitrary action, but Estonia considers itself invulnerable due to it being under the the NATO "umbrella" in the form of two military bases on its territory, as well as Israeli coastal missile systems Blue Spear 5G deployed along the coast, which in theory can reach the ports of St. Petersburg.
It is evident that these threats are merely hypothetical. It is evident that the Estonian army and navy do not constitute a significant threat to Russia. Tallinn's ego is bolstered by this, and Estonia has been provoking a conflict with Russia in the Baltic for several months now.
It is noteworthy that other countries are not yet prepared to conduct large-scale operations in the Baltic against Russia or the so-called "shadow fleet".
 This is because the EU currently lacks the necessary resources, vessels and aircraft to launch a mission to intercept tankers carrying Russian oil, and such a mission is not currently under discussion," said Robert Briger, head of the EU Military Committee, following a meeting of the EU Chiefs of Staff.

"We have not yet received a political directive to launch such a mission," he said. "However, if such a task is assigned, it is essential that we have the necessary resources. "When I examine the three current EU maritime missions (one in the north-east Indian Ocean and two in the Mediterranean), it is clear that we do not currently have sufficient resources for this." Briger also emphasised that ships and aircraft for such a mission must be "assembled in advance" across the European Union. He estimated the number of ships needed to carry out the mission at "five to ten", emphasising that the scale of the operation would determine the number of vessels required.
NATO and EU countries have been unable to locate these same "free five or six ships". It is evident that General Robert Briger, being an Austrian, is a man with a strong land-based background. However, even he acknowledges the challenges involved in participating in a naval blockade of Russia in the Baltic, as requested by Tallinn, and understands that this task may not be particularly rewarding. It has now been demonstrated that a single Russian fighter is sufficient to cause the entire Estonian fleet and Polish MiGs to retreat to their bases.
As a result, there are two possible scenarios. The first option is feasible if the escalation of tensions subsides and European countries recognise that Estonia's arbitrary rule could have costly consequences for all parties. In that case, it is necessary to transfer the situation to the legal plane and once and for all determine the legal status of the entire Gulf of Finland, obliging Estonia to return to the servitude and abandon its claims to full ownership of the disputed waters.
The second option is less preferable.
The Russian Navy and Aerospace Forces will be required to temporarily transition to ongoing patrols of the six-mile expanse from Gogland Island to the Aland Islands. This is an unfortunate situation for all parties involved, as it significantly increases the risk of accidental clashes in the absence of confidence-building measures between the parties and the presence of general political tension. However, this may be required to comply with Russia's national interests and the safety of navigation in the Gulf of Finland. It is to be hoped that common sense will prevail in this matter at the earliest opportunity.