The EU’s 18th Sanctions Package Lookback Started. Trading Russian Products? You’re At Risk.

The EU’s 18th Sanctions Package Lookback Started. Trading Russian Products? You're At Risk.

What’s inside?

    21 January 2026. Mark the date.

    On that day, the EU’s 18th Sanctions Package triggers a rule that will upend global petroleum compliance: any refined product containing Russian-origin crude — processed anywhere, by anyone — becomes illegal to import into Europe.

    The 60-day lookback started 21 November 2025. You’re already inside the window.

    Most operators don’t know it yet. But the exposure is real, it’s growing, and it cannot be solved with conventional compliance tools.

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    The Problem Hiding in Plain Sight

    Russian crude hasn’t stopped flowing, it’s just learned to disappear.

    Over 1,000 vessels now operate in a shadow fleet: false flags, shell companies, forged documents. They move crude through transshipment hubs, mixing zones, and dark channels that evade traditional monitoring.

    The numbers tell the story:

    • ~30 refineries worldwide are already processing Russian feedstock through direct or indirect routes.
    • 91% of global dark-activity events detected by Windward this year trace back to Russian or Iranian networks.
    • Identity laundering and false registry documents have become standard practice.

    What does this mean for you?

    It means your supply chain is contaminated by design. A single cargo with obscured origins can taint entire product lines. And under the new rule, ignorance is not a defense.

    Three Risks You Cannot Ignore

    1. Refinery-Level Contamination

    It’s not enough to know your supplier. You need to know what crude they’re running, and where it came from. One blended cargo can compromise your entire trading position.

    2. Molecule-Level Traceability

    Traditional compliance stops at the vessel. The new regulation goes deeper: it follows the molecules. If Russian crude went into the refinery, the product is prohibited, no matter how many borders it crosses afterward.

    3. Invisible Chokepoints

    Ship-to-ship transfers. Blending hubs. Ports designed for opacity. These nodes determine your risk profile now. And most operators have zero visibility into them.

    The commercial consequences: detained cargoes, broken contracts, market exclusion.

    The strategic threat: enforcement actions that cascade through finance, insurance, and customs.

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    The Intelligence Gap Is Closing Fast

    You cannot navigate this with spreadsheets and self-reported data. The networks moving Russian crude are purpose-built to defeat conventional screening.

    Windward’s Global Exposure Report gives you what static compliance tools cannot: a complete, data-driven map of where Russian molecules are moving, how they’re being concealed, and which operators are exposed.

    What’s Inside:

    Refinery Risk Profiles
    ~30 high-risk facilities currently receiving Russian crude, mapped with sourcing pathways, exposure levels, and deep behavioral analysis of the dark fleet movements.

    Molecule Tracking Models
    See how refined products legally cross borders while carrying prohibited Russian-origin crude, and why vessel checks alone won’t catch it.

    Deceptive Shipping Networks
    Full visibility into dark operations, false flags, STS transfers, and the “molecule laundering” infrastructure keeping Russian crude in global supply chains.

    EU Import Pathway Analysis
    Understand how contaminated products reach European ports despite surface-level compliance, and where the gaps are in your screening process.

    Real-World Case Study
    A detailed breakdown of how origin risk is hidden in practice, with actionable detection strategies.

    Custom Exposure Blueprint
    The report becomes your entry point for a tailored risk assessment across your fleet, counterparties, and trade flows.

    Why This Matters Right Now

    The question is no longer “Is this vessel sanctioned?”

    It’s “Where did these molecules come from?”

    Most compliance systems weren’t built to answer that. And by the time enforcement begins, it will be too late to retrofit your operation.

    The winners in this shift will be the operators who treat origin intelligence as strategic infrastructure.

    Windward’s Global Exposure Report gives you that infrastructure: decision-ready intelligence on where the risk is, how it’s moving, and what you need to do about it.

    The Clock Started Two Days Ago

    Enforcement begins in 58 days.

    But exposure? That’s already here.

    Get the Global Exposure Report Now

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