Maritime Sanctions

OFAC and European Allies Tighten the Net on Russian Oil Trade

In the last several weeks, U.S. and European regulators moved to tighten enforcement of maritime sanctions on Russian oil exports, blacklisting additional companies, vessels and individuals while regional governments scrubbed each other’s lists. Overall market data showed Russian crude exports reacting negatively to the latest of these measures; an incident involving one of those tankers in the Black Sea underscored how their operational and security risks were rising.

United States

EU and Global Regulators Step Up Sanctions Enforcement against Russian Shadow Fleet

The European and international authorities escalated sanctions pressure against Russia’s shadow fleet operations in late November 2025. The EU General Court dismissed cases against challenges to sanctions listings while coordinated efforts between OLAF and Europol targeted networks involved in circumvention attempts. Ukraine sanctioned 56 vessels involved in illegal port calls. Canada tripled its shadow fleet designations to 100 vessels.

Shadow Fleet

US and EU Reinforce Russia Energy Sanctions as Shadow Fleet Crackdown Increases

Between November 15 and 22 2025 both the US and EU use sanctions on Russian energy exports tripling down on energy sanctions and OFAC designating Rosneft and Lukoil whilst adding 557 vessels to its shadow fleet listings. These were carried out together and perhaps signal a shift away from the vessel by vessel sanctions strategy and moving more towards disrupting energy rather than vessels.

China

US Suspends China Vessel Fees as Maritime Trade Tensions Ease; UK Strengthens Russia Sanctions Enforcement

Following the conclusion of trade discussions between President Trump and President Xi, the United States for one year as of November 10 suspended Section 301 vessel fees on China-linked vessels. In other developments, the UK published extensive guidance regarding how Russia seeks to evade sanctions in maritime sectors focusing on common methods of circumventing sanctions.