| United States oil blockade during Operation Southern Spear | |
|---|---|
| Part ofOperation Southern Spear andUS military buildup in the Caribbean | |
| Type | Ship seizure |
| Location | Caribbean Sea off the coast of Venezuela |
| Planned by | |
| Target | Sanctionedoil tankers trading in and out ofVenezuela |
| Date | December 10, 2025 (2025-12-10) − present (2 months and 4 days) |
| Executed by | |
| Outcome | 8oil tankers intercepted by the United States[1][2] |
| Casualties | None |
As part ofOperation Southern Spear, theUnited States enacted ablockade on sanctionedoil tankers traveling in and out ofVenezuela on 17 December 2025, after placingadditional sanctions affecting oil trade with the country. A week before announcing the blockade, the US seized theoil tankerSkipper in theCaribbean Sea off the coast ofVenezuela on 10 December, and then focused its military efforts on intercepting and pursuing other tankers trading with Venezuela. On 7 January 2026, the United States boarded and seized the Russian oil tankerMarinera (formerlyBella 1) in the Atlantic near Iceland and the Panama-flaggedMSophia in the Caribbean Sea.
Skipper had been sanctioned by theUnited States Department of the Treasury in 2022 for alleged involvement in an oil traffickingshadow fleet of vessels involving theIslamic Revolutionary Guard Corps andHezbollah.Marinera andSophia had also been sanctioned by the Treasury Department.
The Venezuelan government condemned the seizure ofSkipper, describing it as an "act ofinternational piracy".[3] UN Security Council members urged restraint and some UN representatives condemned the naval blockade, and analysts said US actions testedmaritime law.
On 7 August 2025, theUnited States Department of Justice raised a reward for the arrest of Venezuelan presidentNicolás Maduro to US$50 million; Maduro was indicted by aUS federal court in 2020 and is accused ofnarcoterrorism and conspiracy to importcocaine to theUnited States.[4][5] The Trump administration accuses the Maduro government of flooding the US with drugs, and has pressured Maduro to step down.[6][7] Over the following months, theUnited States Navy conducted itslargest naval deployment in theCaribbean Sea since theCuban Missile Crisis in 1962.[8] As a part of the naval deployment, the US beganlaunching air strikes on allegeddrug trafficking vessels in the Caribbean Sea in September. By 10 December, the United States had carried out 22 air strikes that killed at least 87 people.[9]
TheVenezuelan economy is heavily reliant on oil exports. Venezuelan oil is extracted and exported byPetroleos de Venezuela (PDVSA), thestate-owned oil company. Oil production has significantly decreased since the early 2000s due tocorruption, PDVSA mismanagement, and sanctions implemented on the country by the United States.[10] In March 2025, United States presidentDonald Trump signedExecutive Order 14245 thatplaced a 25% tariff on any country that imported Venezuelan oil due to Venezuela being "very hostile".[11] In August, Venezuelan defense ministerVladimir Padrino López announced that theBolivarian Navy of Venezuela would be deployed to protect Venezuela's main oil hub.[12] Maduro said in October 2025 that the US wanted to seize Venezuela's oil and that theBolivarian Army of Venezuela had been mobilized to repel a land invasion.[13]
The Russian tankerSeahorse, sanctioned by the European Union and the UK, attempting to delivernaphtha (a product necessary to help export Venezuela's heavy crude) to Venezuela was forced several times byUSS Stockdale to turn back towards Cuba,[14] although it eventually reached Venezuela in November 2025.[15][16]
Skipper, previously namedAdisa (IMO number 9304667), is owned by Triton Navigation Corp., based in theMarshall Islands[3][17][18] and operated byNigeria-based Thomarose Global Ventures.[19] At 310,309DWT, it was built byImabari Shipbuilding atSaijō, Ehime, Japan, in 2005 as yard number 2507, namedToyo and managed by the JapaneseNYK Line.[20] The supertanker is aVery Large Crude Carrier (VLCC), making it too large for some ports.[21]
In November 2022, theUnited States Department of the Treasury placed sanctions againstAdisa, for allegedly being involved in an oil smuggling network that financed both theIslamic Revolutionary Guard Corps andHezbollah.[3][18] The network was led by aUkrainian citizen living inSwitzerland, Viktor Sergiyovitch Artemov, who was sanctioned byOffice of Foreign Assets Control.[22] Artemov was a Russianoil magnate and was accused by the US of coordinating a global Iranian "oil smuggling network" with the help of Triton Navigation.[23]
According to aNew York Times analysis of satellite imagery and data from TankerTrackers.com,Skipper issued falsetransponder readings from October to December 2025 that falsified the ship's location. TankerTrackers.com co-founder Samir Madani referred toSkipper as being part of a "globaldark fleet" of tankers that falsify their location information.[24] Moments before the seizure, the tanker was flying theGuyanese flag, despite not being registered in that country.[25] Reportedly,Skipper docked at least twice in Iran since July 2025, and inHong Kong in August 2025.[22]
On 10 December, tenMaritime Security and Response Team personnel from theUnited States Coast Guard (USCG), ten special operations personnel from theUnited States Marine Corps (USMC), and a number ofspecial operations personnel aboard two helicopters launched fromUSSGerald R. Ford boarded and took control ofSkipper shortly after it left a Venezuelan port.[3][26]
Skipper had leftPuerto José in Venezuela on 4 December with about 1.8 million barrels of crude oil fromPDVSA.[17][27] Soon after its departure, nearCuraçao, the tanker offloaded a portion of its oil to another ship, Neptune 6, which was en route to Cuba.Skipper then turned east, headed towards Asia. The oil tanker was in international waters betweenGrenada andTrinidad when it was boarded by US forces.[27][28]
According to US attorney generalPam Bondi and anonymous US officials,Skipper was seized in accordance with a seizure warrant issued two weeks earlier by a federal judge for allegedly transporting "sanctioned oil".[10][27][29] The ship was seized on the day the warrant was set to expire.[30] Anonymous US officials stated toThe New York Times that the sealed warrant was issued "because of the ship's past activities smuggling Iranian oil, not because of links to the Maduro government", while Bondi stated it had transported both Venezuelan and Iranian crude.[10][29]
Bondi posted a short video excerpt of the seizure onX, adding that it was "conducted safely and securely" and was part of an investigation "to prevent the transport of sanctioned oil".[3][8] According toThe New York Times, three anonymous United States government officials saidSkipper's crew did not resist, there were no casualties, and they expected that more seizures would occur in the following weeks as "part of the administration's efforts to weaken Mr. Maduro's government by undermining its oil market".[10]
The US planned additional seizures of vessels transporting Venezuelan crude.[31][32]
On 20 December, the USCG boarded a second ship, thePanama-flaggedCenturies (IMO number 9206310[33]), carrying 1.8 million barrels of crude oil off the coast of Venezuela,[34] reported as "intercepted" by Reuters.[35] According toThe Washington Post, neither the vessel nor its owner are sanctioned entities, and an unnamed source said the boarding was based on a history of the vessel transporting oil to China, and a "right to visit" law that "allows a warship to board and inspect a vessel it suspects is engaging in illicit activity".[34] Permission to board was obtained from Panama,[34] which later stated that the vessel had violated Panamanian maritime law by turning off its transponder while sailing with crude.[36]Centuries had a history of faking its location.[37] As of 22 December, it was not clear if the vessel would be released or when.[38] In February, the ship was reported to be moored at theGalveston Offshore Lightering Area.[39]


The USCG had been pursuing a third VLCC,Bella 1 (IMO number 9230880),[33] since 20 December 2025, from the Caribbean through the Atlantic Ocean.[40][41] The tanker had previously transported Iranian oil, and was en route to load Venezuelan oil purchased by a company associated with therecently-sanctioned Panamanian, Pedro Carretero.[42] The vessel was sanctioned by the US for "allegedly carrying black-market Iranian oil on behalf of ... Hezbollah and theHouthis" and "has links to theQuds Force".[40] The tanker is owned by Louis Marine Shipholding Enterprises, a Turkish company, sanctioned by the US Treasury in 2024.[43] The US had a seizure warrant forBella 1, which had a history of spoofing its location, was sailing without a valid flag, and did not submit to boarding.[40][42]
Heading for Venezuela with no cargo, the ship's crew resisted boarding on 20 December and the vessel made a U-turn with the USCG in pursuit.[43][44] The USCG requires aMaritime Special Response Team to intercept a hostile ship.[43][44] Officials toldThe Wall Street Journal the team was in place, but because the tanker was old and not carrying oil, "there has been some debate within the Coast Guard and the Navy over whether the tanker should be captured".[40]
ARussian flag was painted on the vessel reported on 31 December in what US officials said was "an apparent attempt to claim protection from Moscow" although "international law stipulates that ships aren't permitted to change their flags mid-voyage unless there is a change of ownership or registration".[40][45] On that day, Russia sent a request through diplomatic channels to ask the United States to stop its pursuit of the tanker.[45] By 1 January 2026, the vessel appeared on theRussian Maritime Register of Shipping under a new name,Marinera, complicating the seizure matter.[46][47][45] On 6 January, it was reported thatMarinera was being escorted by a Russian submarine and a navy vessel.[48][2] On that day, theRussian Foreign Ministry announced it was monitoring the situation, with US officials confirming Russia had asked the US to stop the pursuit.[2] The tanker appeared bound on a voyage towards a Russian port in the Arctic.[49]
TheUnited States European Command (EUCOM) announced on 7 January 2026, thatMarinera had been seized by the USCG cutterMunro in the Atlantic Ocean waters between Iceland and Scotland, traveling northward and eastward;[50] an unnamed US official toldThe Washington Post that the vessel was secure and the Russians had not interfered with the seizure.[41] US military aircraft and special operation forces, includingNavy SEALs, were reported to have been prepositioned in Scotland to board the vessel, which was boarded by helicopter.[45]Boeing P-8 Poseidon,Lockheed AC-130J andPilatus U-28A Draco aircraft assisted the helicopter boarding.[2][51] The United Kingdom acted as a supporting force by contributing a number ofRoyal Air Force (RAF) surveillance aircraft to monitor and assist the seizure, while the replenishment vesselRFATideforce was provided to support US vessels. Icelandic media reported that the seizure happened in international waters within Iceland'sexclusive economic zone, with theIcelandic Coast Guard monitoring the vessel but not intervening in the seizure.[52][53]
Russia accused the US of "outright piracy" in violation of theUnited Nations Convention on the Law of the Sea, and demanded that Russian members of the crew berepatriated.[54] TheRussian Ministry of Transport stated that previously the vessel had received a temporary permit to sail under the Russian flag, in accordance with both Russian and "international" law.[55] USDepartment of Homeland Security (DHS) SecretaryKristi Noem justified the interception by claiming that the Marinera was "responsible for transporting sanctioned oil from Venezuela and Iran".[56][57] The US had previously cited the alleged statelessness of the vessel as justification for the seizure.[56] Unnamed US officials indicated that the seizure was meant to deter other sanctioned tankers from changing their flag to the Russian flag to evade sanctions.[45]Marinera was described by the BritishSecretary of State for DefenceJohn Healey as being part of "shadow fleet activity", which he also called "a sanctioned, stateless vessel".[58][56]
The crew was reported to consist of 17 Ukrainian, six Georgian, three Indian and two Russian citizens, with the captain being Georgian.[b][60][61] The Russian Foreign Ministry called the potential legal prosecution of the crew by the US "categorically unacceptable".[62] On 9 January, the Russian Foreign Ministry announced that the United States had decided to release the two Russian citizens aboard the vessel after appealing to Trump.[63]Marinera was moored on 13 January in theMoray Firth, northeastern Scotland.[64] While the First Minister of Scotland complained he had received no advance notice from the British government regarding the mooring, the British government said the ship had entered UK waters to replenish essential supplies, including food and water for the crew.[65] On 16 January, theBBC reported thatMarinera would be taken to the US to be "subject to a judicial forfeiture process" and that the individuals involved in its attempt to flee would be prosecuted by American authorities.[66] The United States had not confirmed whether it had planned to release the Russians by 20 January, leading Russian foreign ministerSergei Lavrov to call on his American colleagues to "fulfill their promises".[67]
On 7 January 2026,US Southern Command (USSOUTHCOM) announced that it had seized the oil tankerM Sophia (IMO number 9289477) in the Caribbean Sea.[2][50] It described the vessel as a "stateless, sanctioned dark fleet motor tanker".[68]M Sophia was flying a Panamanian flag and reportedly had its transponder off for approximately five months before being seized.[69] Unnamed US officials indicated on 28 January thatM Sophia would be returned to Venezuelan authorities.[70]
On 9 January, USSOUTHCOM announced that it had seized MVOlina (IMO number 9282479) in the Caribbean in a joint operation with the USCG.[71][72] The oil tanker was reported to be flying the false flag ofTimor-Leste and left Venezuela fully loaded with sanctioned oil.[71] The seizure was carried out by sailors and marines from USSGerald R. Ford.[73] TheAframax tanker[72] was previously namedMinerva M and sanctioned by the US in 2021,[73] and also by the UK and EU.[72]
After Trump stated the vessel's departure from Venezuela was unauthorized, andOlina had been seized "in coordination with the interim authorities of Venezuela",PDVSA announced the tanker was being returned to Venezuela as part of a joint operation with the US. Trump said: "The oil will be sold through the GREAT Energy Deal, which we have created for such sales".[74][75]
On 15 January 2026, USSOUTHCOM announced it had seizedVeronica (IMO number 9256860), a crude oil tanker, in the Caribbean.[76] They said the ship was in defiance of Trump's "quarantine of sanctioned vessels". While the oil tanker was sailing under the flag of Guyana, theInternational Maritime Organization's database indicated it was previously registered in Russia under different names.[77][78]
On 21 January, USSOUTHCOM announced it had seized a seventh tanker in the Carribbean,Sagitta (IMO number 9296822), "without incident".[79] It indicated that the tanker was "operating in defiance of President Trump’s established quarantine of sanctioned vessels in the Caribbean".Sagitta was owned and registered by a Hong Kong-based company and was sanctioned by the US Treasury in the wake of the2022 Russian invasion of Ukraine.[80][81] The vessel was sanctioned while flying the Panamanian flag, and was seized while reportedly flying the Liberian flag.[80][81] At the time of capture, the ship was also in the sanctions lists of Australia, Canada, the European Union, New Zealand, Switzerland, Ukraine, and the United Kingdom.[82]
On 9 February,United States Indo-Pacific Command (INDOPACOM) directed an overnight boarding and capture of the Suezmax tankerAquila II (IMO number 9281152) in the Indian Ocean. The vessel had previously departed Venezuelans waters in January 2026, with approximately 700,000 barrels of crude oil headed for China. According to Defense Secretary PeteHegseth this was against the "quarantine of sanctioned vessels in the Caribbean."[83]
| No. | Vessel | IMO number | Size | Date | Location | Oil cargo (mil.bbl) | Sanctions | Notes and sources |
|---|---|---|---|---|---|---|---|---|
| 1 | Skipper (Adisa) | 9304667 | VLCC | 2025-12-10 | International waters between Grenada and Trinidad | 1.85 | [3][18] | |
| 2 | Centuries | 9206310 | 2025-12-20 | Near Venezuela | 1.83 | — | Apprehended as a "False flag ship"[84][85] | |
| 3 | Marinera (Bella 1) | 9230880 | 2026-01-07 | Atlantic Ocean, between Iceland and Scotland | 0 | [86][87][88][89] | ||
| 4 | M Sophia | 9289477 | Caribbean Sea | 1.8 | False identity asVarada Blessing[89][90] | |||
| 5 | Olina (Minerva M) | 9282479 | Aframax | 2026-01-09 | 0.7 | Returned to Venezuela in a joint operation[72][91][75] | ||
| 6 | Veronica | 9256860 | 2026-01-15 | 0 | [76] | |||
| 7 | Sagitta | 9296822 | 2026-01-20 | [92][93] | ||||
| 8 | Aquila II | 9281152 | Suezmax | 2026-02-09 | Indian Ocean | 0.7 | [83][94] |
The day after theSkipper seizure,additional sanctions targeting Maduro's family and oil shipments were imposed by the US,[95] intent on placing financial pressure on Maduro via "maximum" enforcement of sanctions.[6][7]Mike Waltz, the US ambassador to theUnited Nations, stated in a December meeting of theUN Security Council that the sanctioned vessels provide the "primary economic lifeline" that furthers Maduro's "ability to sell Venezuela's oil", enabling "his fraudulent claim to power and his narco-terrorist activities".[5]
Among those sanctioned were six companies and six vessels that had recently transported Venezuelan crude, and Ramón Carretero Napolitano, a Panamanian who allegedly had business ties to Maduro's family involving oil.[31][96][97]
On 17 December, Trump announced a "blockade" targeting sanctioned oil tankers trading in and out of Venezuela.[98] Because the action is limited to sanctioned oil tankers, it is better described as aquarantine; ablockade is an act of war, while enforcing sanctions is a legal matter.[99][100][101] One week later, US officials said Trump had ordered the "military to focus 'almost exclusively' on interdicting Venezuelan oil", without specifying what that exclusive focus meant.[6]
After thecapture of Nicolás Maduro by US Forces on 3 January 2026, at least 16 tankers fled Venezuelan ports as of 5 January in an attempt to evade the US quarantine by heading in different directions at the same time. They tried to avoid detection by transmitting false names and position data or turning off theirAIS transmitters; 15 were under previous sanctions.[1] ANew York Times article cited sources who stated the ships did not act upon orders of acting presidentDelcy Rodríguez, but were controlled by sanctioned businesses and individuals close to Maduro.[1] Oil industry sources stated that the tankers were "contracted by the oil tradersAlex Saab and Ramón Carretero" and that by coordinating their departure, the vessels could overwhelm the quarantine;Carretero was sanctioned by the US in December 2025.[1]
The interdictions have led to a sharp decline in crude exports, as fears of seizure have caused several tankers, some of which are sanctioned, to remain in Venezuelan waters. Several oil tankers en route to Venezuela also made U-turns or halted their navigation following the interdictions.[102] As of 24 December, only two oil tankers carrying PDVSA crude have attempted to enter international waters; one of these,Centuries, was also intercepted. More than 30 ships in Venezuela that are sanctioned by the United States could also be seized, according to Reuters.[103]
As excess crude accumulated, PDVSA began to drain onshore oil storage to oil tankers in order to avoid cutting production.[104] On 28 December PDVSA began to shut down wells in theOrinoco Belt, an action seen as a last resort due to the high costs and logistical challenges associated with restarting them.[105]
Only oil tankers linked toChevron Corporation could freely travel through international waters with Venezuelan crude.[103][c] Chevron spokesperson Bill Turenne reported that its operations in Venezuela continued without disruption.[17]
Morningstar DBRS stated in January 2026 that heightened geopolitical tensions and enforcement actions linked to Venezuela have elevated risks for the global property and casualty insurance sector, particularly in specialty lines such as marine and aviation insurance with exposure to Caribbean shipping lanes and airspace coverage. While "direct exposure to Venezuela appears limited for most international insurers, regional spillovers matter because of increased geopolitical tail risks".[109]
The BBC characterized the seizure and additional sanctions as a "sharp escalation in the US pressure campaign against Maduro".[110]The Wall Street Journal described a "paralyzed tanker traffic" to Venezuelan ports—also documented by Reuters[32]—as "an existential crisis for a regime that runs on oil revenue" that "creates an escalating series of crises" that experts said could be destabilizing.[111]
China buys most of Venezuela's oil at discounted prices.[112] US actions could aggravate tensions between the US and China over control of thePanama Canal.[112]
Representatives of theOffice of the United Nations High Commissioner for Human Rights (OHCHR) condemned the sanctions and quarantine, saying the US is "violating fundamental rules of international law".[6][113] Other analysts say the US has never ratified theUnited Nations Convention on the Law of the Sea (UNCLOS), but its novel actions in the Venezuela case will test established maritime practices and may encourage other countries to seize vessels in international waters.[114]
International law scholars have broadly agreed that the boarding ofSkipper was made in accordance to UNCLOS due to the ship flying a Guyanese flag despite not being registered there, thus making it stateless.[115][116] However, several highlighted that the extent of the boarding party's jurisdiction over the vessel, people and cargo is not settled, because while some states adhere to the view that a boarding party has total jurisdiction over a boarded stateless vessel, others adhere to a more limited jurisdiction interpretation.[116][117]
When Trump confirmed the seizure ofSkipper, he stated that "we've just seized a tanker on the coast of Venezuela—a large tanker, very large, the largest one ever seized actually" and that it was "seized for a very good reason".[8] When Trump was asked what the United States would do withSkipper, he responded "we keep it, I guess".[27] Trump administration officials likeKristi Noem andKaroline Leavitt connected the oil tanker's seizure to the administration'swar on drugs in Latin America.[118]
Pete Hegseth, theUnited States Secretary of Defense, wrote that – as part ofOperation Southern Spear – the US would "unflinchingly conduct maritime interdiction operations ... to dismantle illicit criminal networks. Violence, drugs, and chaos will not control the Western Hemisphere."[119]
From theRepublican Party, SenatorRoger Marshall told reporters that the United States "should be pushing back on Venezuela", adding that he was "concerned about the drug cartel that is running" Venezuela, referring toCartel of the Suns.[9] SenatorRand Paul toldNewsNation reporter Hannah Brandt that the seizure "sounds a lot like the beginning of a war".[9] RepresentativeRick Crawford told NewsNation'sElizabeth Vargas that the seizure was part of a "ongoing action" against Maduro's government, adding that it was "a pretty strong signal to Maduro".[120]
From theDemocratic Party, SenatorChris Coons also told NewsNation that he was "gravely concerned that [Trump] is sleepwalking [the United States] into a war with Venezuela".[9] SenatorChris Van Hollen stated that seizure ofSkipper demonstrated that the Trump administration wanted "regime change [in Venezuela]—by force".[121]
The Venezuelan government "strongly denounced and repudiated" what it considered to be "a shameless robbery and an act ofinternational piracy";[3] according to Reuters, "legal specialists said it did not fall under such a definition under international law".[32] Maduro's government stated that it would "defend its sovereignty, natural resources, and national dignity with absolute determination".[122] It accusedTrinidad and Tobago of participating in the ship's seizure, without saying how they had participated, and canceled all natural gas agreements between the two countries.[123]
Following the announcement of the naval quarantine,Venezuela's National Assembly, controlled by Maduro's party, introduced and passed in two days a bill to criminalize the support, financing or participation in "acts of piracy, blockades or other international illegal acts"; the Associated Press stated that opposition leaderMaría Corina Machado has supported the vessel seizures.[5]
Venezuelan navy vessels began to escort oil tankers carrying Venezuelan petroleum products, though have been limited to unsanctioned tankers[124] and have been contained to the country'sterritorial waters.[106]
The government ofGuyana stated thatSkipper was falsely flying theflag of Guyana as it was not registered in the country.[125]Cuba'sforeign ministry called the oil tanker's seizure an "act of piracy and maritime terrorism," aimed at obstructing Venezuela's right to free trade.[126]
China condemned the United States for seizing oil tankers in December 2025, stating the action was in violation of international law. In a subsequent diplomatic call between Beijing and Caracas, the two countries' top diplomats reaffirmed China's opposition to unilateralism and bullying.[127]
Iranian Foreign Ministry spokesperson,Esmail Baghaei, condemned the US seizure of the oil tanker as "an act of piracy" that he said had no legal basis under international law and that all countries should condemn.[128]
Russia's foreign ministry expressed support for Maduro's government and called the US action "lawlessness in the Caribbean Sea, where long-forgotten theft of other people's property, namely piracy, and banditry, are being revived".[129]
At a special meeting of the UN Security Council in December 2025, other countries supported concerns over maritime law and member sovereignty; Panama and Argentina were among the countries supporting the US.[5][130]
Centuries, which loaded in Venezuela under the false name "Crag" and is part of the dark fleet, was carrying some 1.8m barrels of Venezuelan Merey crude oil bound for China, according to internal documents from state oil company PDVSA, the oil's seller.
The question of statelessness is central to the recent US boardings. Under UNCLOS, any warship may board a vessel on the high seas if it is stateless, meaning it is not lawfully registered with any country or is falsely claiming a nationality. [...] This appears to have been the case with several recent boardings linked to Venezuela. In one instance, a vessel falsely claimed it was Guyana-flagged. Where a vessel cannot demonstrate a genuine flag state, it may be treated as stateless and boarded under international law.
Some States hold that stateless vessels are subject to the jurisdiction of any State and therefore may be arrested by any State as they "enjoy the protections of none." Other States believe that statelessness itself does not create such a vast entitlement, only that it removes the barrier of exclusive flag State jurisdiction, allowing other States that have some other jurisdictional nexus to the vessel, such as the citizenship of the people onboard, the citizenship of the vessel owners, etc., to have enforcement options. Because States continue to adhere to each of these competing views, international law has not developed a uniform rule for this issue. So long as the rule remains unsettled, both options remain legally supportable under international law.