EDINBURGH / WASHINGTON — A diplomatic and legal dispute has emerged between the United States and Scotland after U.S. authorities transferred the captain of a Russian-flagged oil tanker to American custody while legal proceedings were underway in Scotland, prompting accusations that Scottish judicial authority was bypassed.
The case centers on the Marinera, a Russian-flagged tanker alleged by U.S. officials to be part of a sanctions-evasion “shadow fleet” transporting oil in violation of international restrictions. The vessel was intercepted by U.S. forces in the North Atlantic earlier this month and later brought to waters off northern Scotland, near the Moray Firth.
The ship’s captain, Avtandil Kalandadze, a Georgian national, became the subject of emergency legal action in Scotland after his wife’s lawyers petitioned the Court of Session to prevent his removal from Scottish jurisdiction. Lawyers argued that once the vessel and crew were effectively within reach of Scottish authorities, any transfer should be subject to Scottish court oversight.
According to court filings, an interim order was sought to halt the captain’s removal. However, U.S. officials informed the court that Kalandadze and the ship’s first officer had already been transferred to a U.S. Coast Guard vessel and were no longer within UK or Scottish jurisdiction. The court subsequently lifted the interim order after being told the men had already departed British-controlled waters.
The transfer has ignited controversy among legal observers and Scottish officials, who say the move raises serious questions about respect for Scotland’s legal processes. While there has been no confirmation of U.S. agents entering Scottish territory to seize the captain, critics argue that the timing of the transfer — while Scottish proceedings were actively underway — effectively neutralized the court’s authority.
U.S. officials maintain that the operation was lawful and part of a broader effort to disrupt illicit oil trafficking networks used to evade sanctions. The tanker is reportedly linked to oil movements involving Venezuela and Russia, sectors heavily targeted by U.S. sanctions enforcement.
The United States Coast Guard has not publicly detailed where the captain is currently being held, but U.S. authorities have indicated he will face proceedings in the United States related to sanctions violations and maritime offenses.
The Scottish Government has not formally announced a demand for the captain’s return, but the case has fueled political backlash and renewed debate over the limits of U.S. enforcement actions near UK territory. Legal experts note that criminal justice is devolved to Scotland, while foreign affairs remain a matter for the UK government, creating a gray zone when international operations intersect with Scottish courts.
For the captain’s legal team, the issue is less about geopolitics and more about due process. They argue that once Scottish courts were seized of the matter, the removal of their client undermined the rule of law and set a troubling precedent for international cooperation.
As diplomatic discussions continue behind closed doors, the case is shaping up as a rare and highly sensitive test of maritime law, sanctions enforcement, and the balance of sovereignty between allies — with implications that could extend well beyond a single tanker off the Scottish coast.
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