Sanctions Enforcement is Evolving – Are You?

At a Glance

• Q1: The EU’s 16th sanctions package blacklisted 73 shadow fleet tankers and banned Russian aluminum imports, while 70% of newly sanctioned maritime companies were based in just five countries.
• Q2: Sanctions enforcement broadened, targeting flag registries, financial services, and port operators. But Western coordination fractured as the U.S. opposed new G7 actions against the shadow fleet.
• Q3: The number of sanctioned vessels surpassed 1,000 across the EU, UK, and U.S., while false flagging surged past 1,000 vessels, and company designations doubled.
• Late October: The U.S. sanctioned Rosneft and Lukoil, while the EU’s 19th package expanded into LNG and added new maritime entities, signaling a renewed focus on energy enforcement.
• 2026 outlook: Sanctions are converging with operational risk. Behavioral evasion, fragmented jurisdictional rules, and document fraud are reshaping due diligence, and static screening isn’t enough.

Why 2025 Broke the Old Sanctions Playbook

Maritime compliance in 2025 evolved so quickly that by the time teams adapted, the landscape had already changed again. Every quarter introduced a new layer of complexity: expanded lists, novel evasion tactics, jurisdictional gaps. For trading firms, risk teams, and anyone involved in maritime due diligence, it became clear that list-based screening tools alone couldn’t keep up.

Windward’s Q1-Q3 2025 Risk Reports tell a story of acceleration, both in enforcement and in the behaviors used to avoid it.

Three Trends Defining 2025 Maritime Sanctions

1. From Vessels to Ecosystems

In Q1, enforcement looked familiar: the EU blacklisted 73 shadow fleet vessels in its 16th sanctions package, and 88% of newly sanctioned vessels were tankers. But by Q2, the sanctions map had expanded. The EU’s 17th package targeted not just ships, but the enablers, including flag registries, financial intermediaries, and port operators.

This trend solidified in Q3. The number of sanctioned companies doubled compared to Q2. Nearly 60% were based in the UAE or the Marshall Islands, reinforcing a shift in regulatory focus from what’s happening on the water to who’s powering it behind the scenes.

Sanctions no longer stop at the vessel – they reach into the ownership, financing, and support layers of maritime trade.

2. Behavioral Risk Is Outpacing Static Screening 

Q1 introduced new complexities like GPS spoofing and suspicious ship-to-ship (STS) transfers in high-risk areas. Q2 saw a spike in behavioral deception – including AIS gaps, GPS jamming, and spoofing – not just in conflict zones, but near key chokepoints like the Eastern Mediterranean and Arabian Gulf.

By Q3, the scale of this trend was unmistakable. The number of falsely flagged ships doubled over nine months, passing 1,000 vessels. These cases reflected a systemic shift toward behavior-based evasion.

The problem? Most screening systems didn’t see it coming – and even when they did, they weren’t equipped to respond.

Compliance teams were overwhelmed by volume and outpaced by velocity. The behavior of bad actors was evolving faster than most tools could track.

3. Divergence and Disruption in Global Enforcement

While the EU and UK aligned more closely – jointly sanctioning over 300 Russia-trading vessels in Q3 – the U.S. pulled in a different direction. For the second quarter in a row, OFAC didn’t issue new Russia-related maritime sanctions, focusing instead on its largest Iran-related action since 2018.

That changed in late October. The U.S. sanctioned Rosneft and Lukoil, Russia’s two largest oil companies, signaling a major escalation in energy-sector enforcement. These measures target the heart of Russia’s export economy, and increase secondary risk for any charterers or traders exposed to those flows.

Meanwhile, the EU adopted its 19th sanctions package, which includes a ban on Russian liquefied natural gas (LNG) transshipments through European ports, ushering in a new phase of energy enforcement. The package also expands vessel sanctions and targets new entities in energy, finance, and shipping, continuing the crackdown on maritime sanctions evasion.

The result is a more fragmented compliance environment. Divergence between jurisdictions, especially on energy flows and shadow fleet enforcement, is making it harder for compliance and trade finance teams to build unified policies across borders. What’s flagged in London might be overlooked in D.C., and vice versa.

How Compliance Leaders Are Responding

For maritime risk teams, charterers, and trade finance professionals, 2025 has exposed a painful gap between static due diligence tools and the fluid realities of sanctions evasion. Traditional list-matching can’t flag a ship switching flags mid-voyage. It won’t alert you when a vessel’s operator is newly blacklisted, or when deceptive behaviors point to sanctioned activity, even before a designation hits.

That’s why forward-leaning organizations are shifting their approach.

They’re embedding behavioral risk insights into pre-fixture workflows. They’re validating documents in real-time. They’re combining vessel screening with entity intelligence, network link analysis, and anomalies, not relying on any one signal, but on converging patterns of risk.

Windward’s Maritime AI™ platform was built for this moment. Windward’s compliance solution detects deceptive shipping practices before they escalate, connects the dots across ownership structures, and continuously updates risk profiles based on real-world behavior. In 2025 alone, Windward flagged over 99% of vessels sanctioned by the EU, UK, and U.S. before their official designation, giving customers a critical window to act early, reduce exposure, and maintain compliance with confidence.

Sanctions enforcement in 2025 redefined the rules of maritime trade. To navigate 2026, organizations will need to evolve just as quickly, with real-time intelligence, proactive compliance, and systems built for constant change.