Liminal Maritime Aggression in the Black Sea: Romania at a Crossroads of Energy Security
AUTHORS: CAm. Fl. (Ret.) PhD. Sorin LEARSCHI, Admiral (Ret.) PhD. Aurel POPA
Introduction
In recent years, the Black Sea has become a space where geopolitical competition, energy vulnerability, and legal ambiguity overlap in a far more intense manner than in other European maritime basins. While, in the classical paradigm, maritime security could be analyzed around relatively stable dichotomies—peace/war, maritime police/armed forces, commercial navigation/military projection—the strategic reality of the region has demonstrated that these distinctions are today subject to continuous pressure. The war launched by the Russian Federation against Ukraine, the economic exploitation of export routes, the use of sea mines, the development of fleets with opaque ownership, navigation interference, and the vulnerability of undersea infrastructure have transformed the Black Sea into a testing ground for actions conducted just below the threshold of open conflict. [1]
In this strategic landscape, Romania can no longer be viewed merely as a riparian state or a passive beneficiary of Euro-Atlantic security. Offshore energy projects, its geographical position at the interface between the Balkans, the eastern flank, and export corridors, as well as its role in the NATO and EU architecture, are altering the strategic status of the Romanian state. The development of the Neptun Deep perimeter, the intensification of naval exercises, participation in the trilateral maritime mine countermeasures group, and interest in strengthening the protection of critical infrastructure indicate that Romania is simultaneously becoming both the object of pressure and an actor in the regional response.[2]
This article first seeks to conceptually clarify what “liminal maritime aggression” might mean in relation to the literature on grey-zone operations, maritime coercion, and the hybridization of conflict. Second, it analyzes how the Black Sea Fleet and Russia’s auxiliary instruments of power can produce strategic effects below the threshold of a classic armed attack. Third, it assesses the implications for Romania, both from the perspective of international law and that of energy security and infrastructure resilience.
The approach has a legal-strategic dimension. It does not confuse doctrinal analysis with military forecasting, nor is it limited to a mere descriptive exposition. On the contrary, it aims to show that, in the context of the Black Sea, the boundary between law and strategy itself becomes a space of competition: actors test thresholds, exploit ambiguities, instrumentalize norms, and attempt to gain advantages without automatically triggering the classic mechanisms of collective response or self-defense.[3]
What is “Zahhakian” liminal maritime aggression?
To avoid any methodological vulnerability, a clarification is necessary: the expression should not be presented as an established term in doctrine, but as an analytical tool proposed to describe a specific pattern of maritime coercion. In this expanded version, the notion is explicitly treated as a heuristic construct, useful for designating repetitive, coercive, and legally ambiguous actions designed to fall between the traditional categories of international law—between maritime policing and the use of force, between an isolated incident and an armed attack, between economic pressure and strategic sabotage. [4]
The “liminal” nature of the concept derives from the idea of the threshold, classically developed in anthropology by Arnold van Gennep and Victor Turner, but transferred here exclusively to the legal-strategic plane. This is not about anthropologizing states or cultures, but about identifying an intermediate state in which actors deliberately construct their freedom of action through ambiguity. Liminality designates, in this sense, the capacity of a course of conduct to produce serious effects without easily being subsumed under a univocal legal category.[5]
The term “Zahhakian” must, in turn, be understood with caution. It refers to the figure of Zahhak/Aži Dahāka from Persian tradition, as depicted in the Shahnameh, and is used here solely as a controlled metaphor for a logic of gradual pressure, resource depletion, and keeping the adversary in a state of repetitive insecurity. There is no intention of cultural essentialization and no stigmatizing extrapolation. The function of the metaphor is strictly heuristic: it allows for the description of a pattern of aggression that does not manifest itself through a single, clear shock, but through a succession of calibrated gestures, each insufficient, taken separately, to justify a major military reaction, but together capable of eroding strategic stability. [6]
From this perspective, liminal maritime aggression can be defined as a pattern of repetitive, coercive, and difficult-to-attribute actions carried out in the maritime environment, designed to exploit the gap between what is strategically effective and what is legally sufficient to trigger harsh responses. It operates in the zone where costs for the adversary rise, but the normative thresholds for escalation remain uncertain.[7]
The Origin of the Concept and Its Transfer from Hormuz to the Black Sea
The concept was outlined in an analysis dedicated to the Strait of Hormuz, where it was observed that a series of actions such as limited sabotage, seizures, naval harassment, administrative conditioning of transit, and the use of intermediary actors produce considerable strategic effects without automatically qualifying as an armed attack. In that analysis, the focus was on the relationship between jus ad bellum, the regime governing passage through straits, and the difficulties of attribution. The Black Sea offers a different but comparable framework in terms of the sub-threshold logic of action: here, pressure is not concentrated on a single legal “chokepoint,” but on an entire complex of infrastructure, trade corridors, exclusive economic zones, and regional security arrangements.[8]
The conceptual transfer from Hormuz to the Black Sea is not a mechanical one. It does not imply that the two regions are identical, nor that the actors would doctrinally follow the same operational patterns. The difference is, on the contrary, instructive. In the Persian Gulf, pressure is exerted around passage through a strait of global importance. In the Black Sea, liminal aggression revolves around a combination of factors: the militarization of Crimea, partial control of access, drifting mines, drone and missile attacks on port infrastructure, disruption of grain exports, the use of a “shadow fleet,” pressure on the information environment, and the vulnerability of energy and undersea infrastructure.[9]
Therefore, the concept’s utility does not lie in a superficial geopolitical analogy, but in the fact that it provides a framework for understanding behavior that deliberately positions itself below the threshold for triggering a major military response, yet above the level of mere administrative friction. In this sense, the Black Sea is today one of the most relevant European theaters for studying liminal conflict.
Liminal Tactics Used in the Black Sea
1. “Shadow fleet” and covert economic coercion
One of the most visible manifestations of contemporary maritime coercion is the use of ships with opaque ownership, volatile registration, uncertain insurance, and risky navigation practices to transport energy resources or evade sanctions. European and American institutions have documented the extent of the so-called “shadow fleet” associated with Russian hydrocarbon exports, and the issue has been perceived not only as one of economic compliance but also as a risk to maritime and infrastructure security. [10] For the Black Sea, the significance of this phenomenon is twofold. On the one hand, it allows for the continuation of financial flows that support Russia’s war effort. On the other hand, it increases the presence of ships that are difficult to control, sometimes with transponders turned off, a history of successive flag changes, and substandard technical specifications, which amplifies the risks to navigation, the environment, and underwater infrastructure.[11]
2. Sea Mines, Drift Hazards, and the Cost of Freedom of Navigation
The Black Sea has been significantly affected by the use of sea mines and their drift into commercial shipping lanes. For this reason, Romania, Bulgaria, and Turkey agreed on January 11, 2024, through the Memorandum of Understanding signed in Istanbul, to establish MCM Black Sea—a trilateral operational group dedicated to combating sea mines. [12] Official Romanian and Naval Forces documents indicate that the group’s purpose is to maintain freedom of navigation through surveillance, reconnaissance, and neutralization of maritime threats, confirming that the mine threat is not merely tactical but also strategic in nature, as it affects confidence in trade corridors and insurance costs. [13]
On July 9, 2025, Romania assumed command of the MCM Black Sea Task Group, and in January 2026 transferred it to Turkey, in accordance with the rotation established by the memorandum.[14] This detail is important not only symbolically. It shows that the reaction of the littoral states has moved beyond the phase of political statements and entered an operational phase, in which maritime security is treated as a regional collective good.
3. GNSS/GPS Interference and the Degradation of Navigation
Interference with satellite navigation systems is another typical tool of the gray zone. Maritime warnings and technical analyses have been reporting incidents of GPS interference in the Black Sea for years, and in 2025 the IMO, ICAO, and ITU expressed “grave concern” regarding the proliferation of jamming and spoofing, which directly impacts the safety of navigation and communications. [15] In the Black Sea region, such disruptions should not be treated as mere technical incidents. They create uncertainty, affect routing, increase reliance on redundant systems, and reduce commercial actors’ confidence in an environment already saturated with risks.
4. Drones, Remote Attacks, and the Ambiguity of Responsibility
The experience of the Russian-Ukrainian war has demonstrated that the Black Sea maritime space is today one of proliferating aerial and naval drones, precision strikes, and continuous pressure on ports and logistics routes. Even when the source of an incident can be more easily identified than in the case of mines or electronic interference, the actors involved often exploit delays in attribution, media confusion, and divergent interpretations to reduce the legal and political costs of their actions.[16]
The Impact on Coastal States and Romania’s Specific Position
Riparian states do not experience these tactics in the abstract, but as a constant reallocation of resources, attention, and security priorities. Romania, Bulgaria, and Turkey are forced to bear the costs of surveillance, patrolling, demining, interoperability, and legal preparation. Turkey, for its part, remains a key actor through the implementation of the Montreux Convention, which the Turkish Ministry of Foreign Affairs describes as an essential element of stability and security in the Black Sea.[17]
For Romania, the implications are even more pronounced. The country faces not only a general risk of regional instability but also a convergence of military security, maritime security, and energy security. If offshore infrastructure and logistics corridors are disrupted, the effects extend beyond the defense sphere to affect investments, energy prices, the commercial attractiveness of ports, and the state’s credibility as a provider of stability. Consequently, Romania simultaneously becomes a coastal state, a transit state, and an infrastructure state.
Legal Ambiguity: Law Enforcement at Sea versus the Use of Force
One of the most difficult issues raised by liminal maritime aggression is the distinction between law enforcement at sea and the use of force within the meaning of the UN Charter. Jus ad bellum does not always provide quick answers for fragmented incidents, and the law of the sea operates in parallel with its own logic regarding control, safety, and jurisdiction.
The UN Charter prohibits the threat or use of force in international relations under Article 2(4), while Article 51 recognizes the inherent right to self-defense only “if an armed attack occurs.” [18] The case law of the International Court of Justice, particularly Nicaragua and Oil Platforms, has reinforced the distinction between mere uses of force and an armed attack, reserving a higher threshold of gravity for the latter. [19] In the maritime context, this distinction is complicated by the fact that numerous incidents can cause economic damage, logistical disruptions, or serious risks to navigation without immediately resulting in casualties or major destruction.
An additional difficulty lies in attribution. Under the law of state responsibility, ARSIWA requires that the wrongful act be attributable to a state and violate an international obligation.[20] In practice, sea mines, electronic jamming, the use of ships with opaque ownership, or sabotage of undersea infrastructure can leave behind a fragmented evidentiary landscape. It is precisely this fragmentation that makes liminal aggression so effective: the legal cost of a response increases, while the strategic cost of inaction grows ever higher.
Romania’s Response: Between Naval Response, Allied Cooperation, and Modernization
Romania has responded with a mix of cooperation, modernization, and strengthening of its maritime presence. This approach can be developed on three levels:
.1. Trilateral cooperation for mine countermeasuresThe January 11, 2024, Memorandum on MCM Black Sea represented the first exclusively littoral allied initiative of its kind in the region.[21] For Romania, active participation and the subsequent assumption of command served a dual purpose: they strengthened the security profile of the Naval Forces and created a pragmatic platform for cooperation with Bulgaria and Turkey in an area where political consensus is easier to achieve than on hard-projection naval issues.2. Allied Presence and Air CoverOn March 31, 2026, the RAF assumed the Enhanced Air Policing mission in Romania, underscoring the continuity of allied coverage on the eastern flank. [22] Even though air policing is not a naval instrument, it indirectly contributes to maritime security through surveillance, deterrence, and the protection of critical infrastructure.
This article should neither overestimate this dimension nor ignore it: in the security landscape of the Black Sea, the distinction between domains is becoming increasingly blurred.3. Modernization of CapabilitiesRomania has invested in coastal systems and in strengthening its maritime presence, and the internal debate regarding the acquisition of new ships, fleet modernization, and increased presence at sea reflects the fact that the Black Sea can no longer be treated as a secondary theater. [23] At the same time, exercises such as Sea Shield contribute to interoperability and the validation of response scenarios in an environment marked by mines, drones, electronic warfare, and infrastructure vulnerability.[24]Protecting critical infrastructure: pipelines, cables, platformsIn the current security environment, critical subsea and offshore infrastructure can no longer be viewed exclusively as an economic or technical issue. Pipelines, data cables, production platforms, and onshore connection points are strategic nodes. In May 2024, NATO officially launched the Maritime Centre for Security of Critical Undersea Infrastructure within MARCOM, precisely to increase situational awareness and strengthen deterrence and defense against vulnerabilities in undersea pipelines and cables. [25]For Romania, this development is particularly relevant. The Neptun Deep project, for which OMV Petrom and Romgaz made the final investment decision in June 2023, is estimated to bring approximately 100 billion cubic meters of gas into production, with first flows anticipated in 2027. [26] Such infrastructure is not merely an energy asset; it is a strategic national and European objective. To the extent that Romania links its energy profile more closely to offshore operations, the obligation to develop capabilities for surveillance, early warning, physical protection, and cybersecurity also increases.
The Cyber Dimension
The cyber dimension must be integrated without exaggeration. Not every threat can be presented as a fait accompli. However, it is indisputable that modern energy and maritime infrastructures depend on digital systems, SCADA, satellite communications, and data flows without which safe operation becomes impossible. For this reason, an attack on contemporary maritime infrastructure is no longer merely physical. It can also target data integrity, the redundancy of command and control systems, and operators’ confidence in the operational picture.
For Romania, this implies closer integration between maritime security and cybersecurity cultures. The protection of submarine cables and offshore platforms cannot be addressed solely through patrols or physical sensors. It also requires testing software resilience, response protocols, auditing critical systems, and inter-agency cooperation among actors in the defense, energy, and cybersecurity sectors.[28]
Developments and Trends: 2026–2030
In this regard, it is reasonable to anticipate that, between 2026 and 2030, the Black Sea will remain a space conducive to gray-zone tactics. More specifically, the following are likely: Furthermore, as Romania advances in offshore exploitation and integration into European markets, the exclusive economic zone will gain greater strategic significance. This does not necessarily mean a dramatic “militarization,” but it almost inevitably implies increased surveillance, improved sensors, and greater preparedness for hybrid incidents.
- maintaining a high presence of mines and the costs of mine clearance;
- intensified use of aerial and naval drones;
- an increased role for the “shadow fleet” in the war economy and in risks to the environment and infrastructure;
- the growing importance of protecting undersea infrastructure;
- a heightened interdependence between military, energy, and cyber security.[29]
Guidance Protocol for Responding to Sabotage or a Major Incident
Such a model could include:
(a) initial detection and stabilization – activation of technical alarm procedures, delineation of the risk zone, suspension of vulnerable operations, and protection of personnel;
(b) preliminary technical assessment – rapid collection of AIS, radar, satellite, hydroacoustic, and cyber data, as well as preservation of evidence;
(c) legal-strategic assessment – provisional classification of the incident: accident, sabotage, hostile interference, use of force, sub-threshold incident;
(d) allied and diplomatic coordination – NATO consultations, information sharing, notifications to relevant maritime organizations, and strategic public communication;
(e) resilience and continuity measures – activation of alternative routes, mobilization of recovery capabilities, and mitigation of economic impact.
Such a framework should not be presented as a panacea, but it has the advantage of showing that the response to liminal aggression does not begin with military escalation, but with reducing the duration of uncertainty and strengthening the evidentiary base.
The Neptune Deep Junction Point and Vulnerability
The connection points between subsea infrastructure and land are often the most exposed areas, as they concentrate both physical and digital vulnerabilities. For a project such as Neptun Deep, the risk is not limited to offshore platforms but also includes pipelines, processing stations, communication nodes, and the logistics chain behind the operation. The vulnerability of such a facility can stem from physical sabotage, hostile surveillance, disruption of control systems, or simple incidents exploited for propaganda to induce panic and mistrust.
Therefore, a serious risk analysis should combine legal, technical, and social perspectives. The law of the sea defines the jurisdictional framework, but real protection depends on institutional interoperability and a culture of security. Furthermore, the participation of coastal communities in reporting suspicious behavior, without militarizing public discourse, can be of practical use in an environment where subtle signals matter.
Local Community Engagement and Societal Resilience
Without turning citizens into a substitute for state functions, it is useful to recognize that fishermen, port operators, technical staff, coastal communities, and private companies can contribute to the early detection of anomalies and to maintaining resilience.
In the context of hybrid threats, society is not only a target but also part of the defense. Critical infrastructure that is insufficiently protected legally, technically, or socially becomes easier to disrupt not only through direct attack but also through fear, disinformation, mistrust, and delayed response. Therefore, societal resilience must be understood as a complementary element of maritime security, not as a rhetorical flourish.
Conclusions and Recommendations
Romania is at a strategic turning point. The Black Sea is no longer merely a problematic neighborhood, but a space for defining its security and energy profile. In this context, the concept of liminal maritime aggression is useful precisely because it describes that continuous, fragmented, and ambiguous pressure that cannot be effectively addressed either through mere declarative diplomacy or through reflexes of automatic escalation.
The central conclusion of the article is that Romania’s vulnerability stems not only from its proximity to a theater of war, but from the convergence of three conditions: the growing importance of offshore energy infrastructure, exposure to sub-threshold maritime tactics, and the need to respond within a legal framework that demands prudence, proportionality, and evidence. It is precisely in this combination that liminal aggression becomes effective: it increases defensive costs, disperses responsibility, and shifts the dispute into the gray zone between incident and aggression.
Several recommendations follow from this. First, Romania must continue to strengthen naval and mine-clearance cooperation with allied riparian states, without abandoning the aspiration for a more robust allied presence in the region. Second, the protection of critical infrastructure must be treated as a matter of national security policy, not as a technical appendage of energy policy. Third, a legal and institutional culture of rapid attribution is necessary, capable of reducing the adversary’s advantage in the zone of uncertainty. Finally, the resilience of society and economic operators must be integrated into the logic of defense, as the boundary between military security and economic security is already, in the Black Sea, a deeply porous one.
Liminal maritime aggression is therefore not merely a metaphor for turbulent times, but a lens through which to view a strategic reality in which stability is no longer destroyed solely by a frontal assault, but eroded gradually, methodically, and deliberately. For Romania, the appropriate response can be neither alarmism nor complacency, but the building of a capacity for deterrence, protection, and resilience that will make its maritime border not Europe’s weak point, but one of its areas of strategic strength.
Selected Bibliography[1] EEAS, EU strategic approach to the Black Sea region (2025), which highlights the risks posed by drifting mines, the “shadow fleet,” hybrid actions, and infrastructure vulnerabilities in the region.
- Charter of the United Nations, adopted in San Francisco on June 26, 1945, entered into force on October 24, 1945.
- Council of the European Union, communications and sanctions packages regarding vessels in the “Russian shadow fleet,” 2025.
- DNSC, public resources on the protection of critical digital infrastructure, accessed April 2026.
- EEAS, EU strategic approach to the Black Sea region (2025).
- European Parliamentary Research Service, Russia’s “shadow fleet”: Bringing the threat to light (November 14, 2024).
- Romanian Naval Forces, official press releases and institutional website, accessed April 2026.
- International Law Commission, Articles on Responsibility of States for Internationally Wrongful Acts (2001).
- Kraska, James and Raul Pedrozo, International Maritime Security Law (Martinus Nijhoff 2013).
- Lott, Alexander and Shin Kawagishi, ‘The Legal Regime of the Strait of Hormuz and Attacks Against Oil Tankers: Law of the Sea and Law on the Use of Force Perspectives’ (2022) 53 Ocean Development & International Law 123-146.
- MApN, “The Signing of the Memorandum of Understanding on the establishment of a Task Force to Counter Sea Mines in the Black Sea,” January 11, 2024.
- MApN, “Romania has taken over command of the MCM Black Sea Task Group,” July 9, 2025.
- Mazarr, Michael J, Mastering the Gray Zone: Understanding a Changing Era of Conflict (US Army War College Press 2015).
- NATO SHAPE, “NATO officially launches new Maritime Centre for Security of Critical Undersea Infrastructure,” May 28, 2024.
- NATO, “NATO launches Baltic Sentry to increase critical infrastructure security,” January 14, 2025.
- OMV, “OMV announces final investment decision taken by OMV Petrom for natural gas deepwater project Neptun Deep,” June 21, 2023.
- Reuters, “Romania to acquire warships to strengthen NATO’s eastern flank,” March 28, 2025.
- Republic of Türkiye Ministry of Foreign Affairs, Implementation of the Montreux Convention, accessed April 2026.
- Royal Air Force, “Strengthening the Shield: RAF Leads NATO Air Policing from Romania,” March 31, 2026.
- Schmitt, Michael N (ed), Tallinn Manual 2.0 on the International Law Applicable to Cyber Operations (Cambridge University Press 2017).
- Schmitt, Michael N, ‘Gray Zones in the International Law of Peace and War’ in The Elgar Companion to International Law and Security (Edward Elgar 2022).
- SHAPE, “NATO officially launches new Maritime Centre for Security of Critical Undersea Infrastructure,” May 28, 2024.
- Skjærvø, Prods Oktor, James R Russell and Djalal Khaleghi-Motlagh, ‘Aždahā’ in Encyclopaedia Iranica (1987, updated 2017).
- Turner, Victor, The Ritual Process: Structure and Anti-Structure (Aldine 1969).
- United Nations Convention on the Law of the Sea, adopted at Montego Bay on December 10, 1982, entered into force on November 16, 1994.
- U.S. Department of the Treasury, “Treasury Intensifies Sanctions Against Russia by Targeting Russia’s Shadow Fleet,” January 10, 2025.
- U.S. Maritime Administration, Safety Alert 2017-005A Black Sea GPS Interference.
- U.S. Maritime Advisory 2024-012, Black Sea and Sea of Azov – Military Combat Operations (September 6, 2024).
- van Gennep, Arnold, The Rites of Passage (University of Chicago Press 2019 [1909]).
- Military and Paramilitary Activities in and against Nicaragua (Nicaragua v. United States of America) (Merits) [1986] ICJ Rep. 14.
- Oil Platforms (Islamic Republic of Iran v. United States of America) [2003] ICJ Rep. 161.
[2] OMV, “OMV announces final investment decision taken by OMV Petrom for natural gas deepwater project Neptun Deep,” June 21, 2023; Reuters, “Romania to acquire warships to strengthen NATO’s eastern flank,” March 28, 2025.
[3] Michael J Mazarr, Mastering the Gray Zone: Understanding a Changing Era of Conflict (US Army War College Press 2015) 1–5.
[4] For the doctrinal background on sub-threshold maritime coercion, see James Kraska and Raul Pedrozo, International Maritime Security Law (Martinus Nijhoff 2013) 3–12.
[5] Arnold van Gennep, The Rites of Passage (University of Chicago Press 2019 [1909]); Victor Turner, The Ritual Process: Structure and Anti-Structure (Aldine 1969).
[6] Prods Oktor Skjærvø, James R Russell, and Djalal Khaleghi-Motlagh, ‘Aždahā’ in Encyclopaedia Iranica (1987, updated 2017).
[7] Michael Schmitt, ‘Gray Zones in the International Law of Peace and War’ in The Elgar Companion to International Law and Security (Edward Elgar 2022) 180–196.
[8] For an extensive analysis of the Strait of Hormuz as a space of sub-threshold coercion, see Alexander Lott and Shin Kawagishi, ‘The Legal Regime of the Strait of Hormuz and Attacks Against Oil Tankers’ (2022) 53 Ocean Development & International Law 123.
[9] U.S. Maritime Advisory 2024-012, Black Sea and Sea of Azov – Military Combat Operations (September 6, 2024).
[10] Council of the European Union, communications regarding sanctions imposed on vessels in the “Russian shadow fleet,” 2025; U.S. Department of the Treasury, “Treasury Intensifies Sanctions Against Russia by Targeting Russia’s Shadow Fleet,” January 10, 2025.
[11] European Parliamentary Research Service, Russia’s ‘shadow fleet’: Bringing the threat to light (November 14, 2024).
[12] Ministry of National Defense, “The Signing of the Memorandum of Understanding on the establishment of a Task Force to Counter the Sea Mines in the Black Sea,” January 11, 2024.
[13] Romanian Naval Forces, “The role of the MCM Black Sea is to ensure freedom of navigation in the Black Sea…,” press release dated January 6, 2026.
[14] Ministry of National Defense, “Romania has taken over command of the MCM Black Sea Task Group,” July 9, 2025; Romanian Naval Forces, press release dated January 6, 2026.
[15] IMO, ICAO, and ITU, Joint Statement on harmful interference to GNSS, March 25, 2025; U.S. Maritime Administration, Safety Alert 2017-005A Black Sea GPS Interference.
[16] U.S. Maritime Advisory 2024-012 (No. 9).
[17] Republic of Türkiye Ministry of Foreign Affairs, Implementation of the Montreux Convention (accessed April 2026).
[18] Charter of the United Nations, Art. 2(4) and Art. 51.
[19] Military and Paramilitary Activities in and against Nicaragua (Nicaragua v United States of America) (Merits) [1986] ICJ Rep 14; Oil Platforms (Islamic Republic of Iran v United States of America) [2003] ICJ Rep 161.
[20] International Law Commission, Articles on Responsibility of States for Internationally Wrongful Acts (2001).
[21] MApN (n 12).
[22] Royal Air Force, “Strengthening the Shield: RAF Leads NATO Air Policing from Romania,” March 31, 2026; NATO Allied Air Command, press release regarding the handover of the Enhanced Air Policing mission in Romania, March 31, 2026.
[23] Reuters (n 2).
[24] Romanian Naval Forces, official website, section on Sea Shield exercises (accessed April 2026).
[25] SHAPE, “NATO officially launches new Maritime Centre for Security of Critical Undersea Infrastructure,” May 28, 2024.
[26] OMV (n 2).
[27] For the broader context regarding Western concerns about critical undersea infrastructure and Russian activity, see NATO, “NATO launches Baltic Sentry to increase critical infrastructure security,” January 14, 2025; as well as analyses dedicated to GUGI and hybrid undersea warfare.
[28] Michael N Schmitt (ed.), Tallinn Manual 2.0 on the International Law Applicable to Cyber Operations (Cambridge University Press 2017); DNSC, public resources on the protection of critical digital infrastructure.
[29] EEAS (n 1); SHAPE (n 25).
[30] See, for the general logic of graduated responses and the reduction of evidentiary uncertainty, Mazarr (n 3); Kraska and Pedrozo (n 4).