As you fly into Malta at night, you can see the dense, bright sparkling lights of the tourist centres of St Paul’s, St Julian’s and Sliema, where the vibrant energy of the land melds into the dark expanse of the sea. Out of the left-hand windows, you may be surprised also to see faint lights, twinkling in the distance where, logic tells you, there should be nothing but ocean, until you hit the western coastline of Crete.
What you are seeing is the shallow waters of Hurd’s Bank, some 16 nautical miles from the coast of Malta. The mysterious lights, singular pinpricks, like so many distant stars, belong to the twenty, forty, or dozens of ships that lie at anchor on the shallows. I cannot be more precise, as nobody knows the exact number. Hurd’s Bank is a curiosity – an unregulated nexus of commercial activity. Orange-red tenders nestle alongside small cargo ships, refuelling them, supplying provisions and crew. Some vessels simply lie up, idle, drifting around on their anchor chains, noses to the wind, waiting for the next job to come along. The ships prefer to anchor on the bank rather than venture into port and incur the associated charges, but many are there for more nefarious purposes.
Hurd’s Bank is approximately 30 to 50 metres deep, roughly circular, and has a diameter of 30 kilometres. It is a large expanse of shallow, international water – some 900sq km – unlike anywhere else in the Mediterranean. A typical cargo vessel would carry over 300 metres of anchor chain, so the bank provides a cheap, convenient and safe anchorage.
Malta’s territorial waters extend 12 nautical miles from its coastline, a space within which it is responsible for all traffic and trade. The Maltese government has made it clear that it considers Hurd’s Bank beyond its jurisdiction and has expressly disclaimed responsibility for whatever happens there. In the first book of my Inspector George Zammit series, Bodies in the Water, one of the plotlines involves Hurd’s Bank as the location of an organised crime group’s oil smuggling operation that our hapless George ends up having to investigate.
This was not a stretch of my imagination. Hurd’s Bank has, since the fall of Gaddafi in 2011, become a centre of fuel smuggling from conflict-ridden Libya and increasingly sophisticated, sanction-busting operations involving Russian oil. Malta is only 200 nautical miles north of the Libyan coast, and there have been strong historic links between the two countries for decades. Mata’s flat-roofed square houses, rocky scrub and urban streets with traditional Arabesque closed, wooden balconies, feel more North African than Italian, despite the coast of Sicily only being 60km to the north.
Libya is an oil-rich country and the 2020 ceasefire in the long-running civil war has largely been successful. This allowed the sanctions blockade to end and the production of crude oil to resume. However, it remains a volatile country, plagued by corruption and powerful militias, making it an unattractive investment proposition. Furthermore, for a country with such plentiful reserves of oil, it only has a limited refining capacity. This has led to Libya being forced to import a large amounts of diesel, which it heavily subsidises. Libya has not sanctioned Russia, so a third of this cheap imported diesel comes down the Black Sea and through the Bosphorus.
It is estimated that 40% of this fuel is diverted away from the domestic market by corrupt officials, militia activity, or black-market purchasers, who sell it on for 15 to 20 times its subsidised purchase price. The Russian fuel is re-exported, transferred between tankers on Hurds Bank. It then arrives in Malta, or other destinations, where it is blended with other market-compliant fuel and sold to unsuspecting customers, who may be unscrupulous fuel brokers, ‘dirty oil’ operators in Italy, or unsuspecting shipping companies and oil traders, duped by forged documentation. In Southern and Eastern Europe, there are a large number of independent garages that are not part of the big networks, where smuggled diesel can easily be sold. It is telling that an Italian official described Hurd’s Bank as a ‘paradiso dei trafficanti’.
Hurd’s Bank also played a role in Russian support for sanctions-hit Venezuela, which was facing a desperate need for specific chemicals, such as naphtha, to dilute its own heavy crude oil for processing and transport. Russia was happy to oblige. In 2019, an estimated 400,000 tonnes of Russian petroleum products were transferred at Hurd’s Bank from smaller tankers to larger vessels for the trip across the Atlantic. Records show a total of 13 tankers were involved in this trade. More recently, in June 2024, a study confirmed Hurd’s Bank was used by Russian tankers to transfer Russian oil destined for several undisclosed African countries.
This trade would not be possible without the existence of the ‘black fleet’ of tankers that move backwards and forwards between Russia and Hurd’s Bank. These aged tankers, many over twenty years old, are bought cheaply, often saving them from the breakers yard. They are usually in poor condition and on the smaller size, so as not to attract too much attention. They are often uninsured, have an opaque ownership structure, usually through offshore companies, and fly a ‘flag of convenience’, meaning they are subject to the lightest of regulatory scrutiny. These vessels frequently change ownership and their chosen ‘flag state’ to frustrate legal sanctions.
When a ship wishes to conduct its business unobserved, it disables its Automatic Identification System (AIS), enabling it to disappear into the vastness of the ocean. Under maritime law, this system should be active at all times, as it identifies the ship and its location, allowing its movement to be tracked by other vessels, helping to avoid collisions. If a small, decrepit tanker, flying the light blue and yellow flag of Palau, or some other Pacific island registry, turns off its AIS when entering the area defined as the ‘black hole of smuggling’, between the Libyan ports of Benghazi and Tobruk, it is a fair bet it is engaged in illegal activities.
Arguably, Malta should play a role in regulating activities on Hurds Bank, which, as well as fuel smuggling, facilitates drug smuggling, weapons trading, people smuggling, and acts as a hub for the migrant business between North Africa and Europe. The Maltese government wrings its hands and pleads it does not have the resources to undertake such maritime policing duties. This might be correct, as Malta’s Maritime Squadron only comprises ten offshore patrol vessels. One could also look at Malta’s woeful record in patrolling the expanse of water between Tunisia and Crete, as part of its search and rescue responsibilities throughout the Southern Mediterranean migrant crisis.
Malta’s ability to manage its regulators and dispense justice has also come in for serious criticism. There have been several reports by the European Commission following the murder of the high-profile journalist, Daphne Caruana Galizia. They found the judiciary is understaffed and the regulators and police were judged to be largely ineffective and not impartial. Court cases take years to complete, and the backlog of cases continues to grow. The country has also been dogged by allegations of large-scale corruption between those in high office and business, and it is known that the Mafia and other organised crime groups operate in Malta. Whether the country could be trusted to police and regulate the activity on Hurd’s Bank remains a moot point.
It is interesting to note that in July 2025, Malta was threatening to veto an EU resolution aimed at lowering the price at which Russian oil could be sold and legally transported by EU-registered shipping. The concern was that this might herald an exit of ships from the Maltese registry, by those seeking a ‘flag state’ not impacted by the rule. This is ironic, given that later in 2025, the capital, Valletta, is due to become home to the UN’s Global Centre for Maritime Sanctions Enforcement, which aims to enforce sanctions, monitor illicit practices, and actively tackle illegal ship-to-ship transfers!
As Malta struggles to shed its reputation as home to a plethora of money launderers and international criminals, its next challenge is how to develop its offshore resources. It is poised to outline plans for an Exclusive Economic Zone (‘EEZ’) which would include the Hurd’s Bank shallows and will give Malta exclusive rights over natural resources beyond the limits of its territorial waters. Malta has plans for wind farms, more fish farms, as well as a hydrogen production facility.
In international waters, -‘the high seas’ – beyond a nation’s territorial waters and any EEZ – the general rule is that a ship is subject to the exclusive jurisdiction of its ‘flag state’. It cannot be stopped or boarded, except in exceptional circumstances, other than by a vessel from its own ‘flag state’. It must be said, it is rare to find a naval vessel from Tanzania, Togo, Belize or Moldova in the Mediterranean!
However, an EEZ will entail far-reaching security obligations, which the Maltese are warily examining. Will the economic benefits outweigh the historical avoidance of security obligations?
When I first arrived in Malta ten years ago, I read the headlines in the newspapers with shock and disbelief. The cult of Prime Minister Joseph Muscat was in full swing and he and his Labour Party governed with a spirit of impunity not seen in Northern Europe. It soon became evident that the plotlines of a dozen crime and adventure books were being served up in the daily newspapers. When Covid struck and I started to writing Bodies in the Water, I eagerly seized the opportunity to explore the world of fuel smuggling, money laundering, Libyan militias, organised crime groups, sanction busting, high level corruption – a world where there is no black and white, where good people do bad things, a world where the moral compass never points to true North. Six books later, I am still writing about it!