Global Exposure Report: The EU 18th Sanctions Package

Executive Summary

This report leverages Windward behavioral data to query Vortexa data and examine the sanctions exposure risk associated with Russian crude oil imports and refined product exports from India, China, and Turkey to the European Union (EU). These countries are key players in Russian crude imports, collectively processing 1.17 billion barrels in 2025. India, the largest importer, faces significant compliance risks, particularly at Reliance Jamnagar refinery, which processes the bulk of Russian crude. Turkey has shown varying compliance, with significant reductions in imports after November 2025. China on the other hand, imports high volumes of Russian crude though minimal refined products are exported to EU markets.

The export of refined products, in particular diesel, and to a lesser extent naphtha and jet fuel, from these countries to the EU also presents risks, with India again dominating at approximately 60 million barrels. Reliance Jamnagar’s refinery is identified as a high-risk facility, with over half of Russian-derived product exports to the EU originating from there. Windward’s tracking reveals extensive use of flags of convenience and high-risk vessels, with 53.1% of Russian crude tankers classified as high-risk.

The report highlights a surge in EU-bound exports just before the sanctions deadline on 21 January 2026, indicating potential stockpiling behavior. This underscores the importance of continued monitoring and sanctions enforcement, particularly through vessel tracking and cargo intelligence, to prevent evasion.

Scope & Focus

This analysis focuses exclusively on three non-G7, non-net-exporting countries – India, China, and Turkey – which collectively dominate Russian crude imports and represent the primary sources of EU-destined refined product exports. The EU 18th Sanctions Package explicitly exempts several countries, key ones being G7 members (US, UK, Canada, France, Germany, Italy, Japan), Norway, and Switzerland, as well as net oil-exporting nations (UAE, Saudi Arabia, Kuwait). India, China, and Turkey, by contrast, face full sanctions exposure for refined products derived from Russian crude. These three nations’ refinery networks – spanning from India’s massive private sector capacity to China’s independent teapot facilities to Turkey’s Mediterranean-focused infrastructure – are identified as the highest-risk vectors for sanctions evasion. Together, they processed 1.17 billion barrels of Russian crude in 2025.

In addition, all numbers and analysis of the Vortexa’s data base were done based on Windward’s behavioral analysis.

Section 1: Russian Crude Oil Imports

1.1 Global Import Landscape

In 2025, India dominated Russian crude imports at 596 million barrels (50.9%), followed by China (442.9M bbl, 37.8%) and Turkey (132.8M bbl, 11.3%). Tracking discharged crude shipments via Vortexa data (by arrival date) and cross-referencing with Windward Maritime Compliance fleet tracking – which has mapped individual refinery terminals and SPMs to link specific ports with refineries – reveals these three nations collectively imported 1.17 billion barrels throughout 2025. This volume constitutes the primary refining base for Russian-origin products destined for EU markets under pre-January 21, 2026 loopholes.

India’s dominance reflects its massive private refining sector, anchored by Reliance Jamnagar, alongside state refiners such as Indian Oil Corporation (IOC), Bharat Petroleum Corporation Limited. (BPCL) and Hindustan Petroleum Corporation Limited. (HPCL) and Nayara Energy (49% Rosneft-owned). China’s 442.9M barrels include both state-owned majors and independent “teapot” refineries in Shandong Province. Turkey’s 132.8M barrels are mainly imported by SOCAR Turkey Aegean Refinery A.Ş. (STAR Refinery) and Tupras Izmit refinery.

1.2 The 60-Day Lookback Period & Top Refinery Compliance

The EU 18th Sanctions Package effective January 21, 2026 bans refined products from Russian crude imported after November 21, 2025, obligating a 60 days non-Russian crude presence to be allowed to export to EU markets. November 21-December 31 arrivals totals around 150 million barrels across all three countries, representing approximately 127 million barrels of refined products subject to EU bans (assuming 85% refining yield). This lookback period reveals divergent compliance patterns detected through Windward’s sanctions risk assessment algorithms:

India: 84.5M bbl (14.2% of annual) arrived in the lookback window. Reliance halted Russian crude at its export-focused Special Economic Zone (SEZ) refinery on November 20, redirecting intake to its domestic-only Domestic Tariff Area (DTA) refinery. India operates under a dual regulatory framework: SEZ units enjoy tax exemptions and export exclusively, while DTA refineries serve domestic markets under standard customs duties. Reliance claims “fully segregated” crude processing between the two facilities. However, verification challenges remain significant — the EU’s enforcement depends on refiners’ self-certification without independent third-party auditing, raising questions about whether physical segregation can prevent Russian crude “leakage” between facilities.

Despite Reliance’s reduction, Nayara Energy maintained intake despite Rosneft sanctions, while Paradip Refinery (IOC) surged to 8.5M bbl, offsetting Reliance’s compliance.

China: 53.3M bbl (12% of annual) arrived post‑November 20. State‑owned refineries reduced intake significantly, while independent refineries in Shandong province – such as Dongying‑area plants operated by Qicheng Petrochemical and Qirun Petrochemical, and Changyi Petrochemical in Weifang – saw their seaborne Russian crude intake fall by around 80% in the lookback period. This decline is consistent with reports that many Shandong “teapot” refiners exhausted their 2025 crude import quotas by October and were forced to cut runs until new quotas were issued, rather than clear evidence of sanctions‑driven compliance. After Beijing granted an additional batch of quotas to non‑state refiners, including Shandong teapots, several independents have reportedly increased crude buying again, primarily of discounted sanctioned grades such as Russian and Iranian barrels.

Turkey: 11.2M bbl (8.4% of annual) post-November 20 – a sharp decline. Both Tupras and STAR Refinery reduced intake 50-55% below normal seasonal levels.

Top 5 Refineries: 2025 vs. Post-November 20 Comparison

*Expected = 16.4% of annual (60 days out of 365). Negative % indicates reduction, positive indicates increase relative to normal pace.

Key Findings:

• Reliance Jamnagar maintained near-normal pace (-1.5%), reflecting DTA-only intake rather than full halt.
• Turkish refineries (Aliaga) showed strongest compliance (-48.9%).
• Yulong Petrochemical increased intake despite UK/EU sanctions (+15.8%).
• Shandong teapots collapsed (-79.2%).

1.3 Vessel Fleet: Systemic Evasion Infrastructure

343 Russian crude tankers called at mapped terminals in 2025, exhibiting systematic evasion characteristics detected through Windward’s sanctions risk tracking:

Flag States: 74% flew flags of convenience (Panama, Liberia, Marshall Islands, Sierra Leone, Malta). Only 2 vessels retained Russian flags.

Sanctions Status: 182 vessels (53.1%) were “high-risk” designated, 116 (33.8%) formally sanctioned (these made 20 port-calls post November 20) – meaning 86.9% exhibited sanctions concerns.

Fleet Profile: Average age 16 years (built 2009), average DWT 154,420 tons (1.1M barrels capacity). This aging profile correlates with end-of-life vessels used in sanctions evasion, where owners accept higher operational risk and environmental liability given vessels’ diminished long-term value.

Section 2: Refined Product Exports to EU Markets

2.1 Overview

This section analyzes exports of petroleum products (CN Code 2710: diesel, gasoline, jet fuel, fuel oil and naphtha) from refineries in India, China, and Turkey processing Russian crude. Under EU Council Regulation 833/2014 Article 3ma (18th Sanctions Package, effective January 21, 2026), these products are banned from EU import.

According to Vortexa data, in 2025 refineries processing Russian crude in India, China and Turkey, exported 100 million barrels of CN 2710 petroleum products to EU markets. India dominated at 61.2 million barrels (61.2%), followed by Turkey at 37 million barrels (37.0%), and China at 1.8 million barrels (1.8%). Product composition was concentrated in diesel/gasoil (60% of total), followed by naphtha (21.6%), gasoline/blending components (8.9%), jet fuel/kerosene (6.0%), and fuel oil (3.4%).

Geographically, exports concentrated in Mediterranean destinations (43.8 million barrels, 43.8%) and Northwest Europe ports including Rotterdam and Antwerp (37.8 million barrels, 37.8%). Black Sea routes accounted for 16.2%, while Baltic ports received 2.2%. This geographic distribution reflects both Turkey’s proximity to Mediterranean markets and India’s established long-haul export infrastructure to Northwest European refining hubs.

2.2 India: Reliance Jamnagar Concentration Risk

India’s 61.2 million barrels represent 61.2% of total EU imports from Russian-crude-processing refineries, with extreme concentration at a single facility: Sikka terminals (Reliance Jamnagar) exported 58.9 million barrels – representing 58.9% of all Russian-derived product exports to EU markets. This singular dependency creates systemic compliance risk for EU energy markets.

The entire compliance framework rests on Reliance’s claimed SEZ/DTA segregation. As noted in Section 1, India operates dual regulatory zones: Special Economic Zones (SEZ) enjoy tax exemptions and export exclusively, while Domestic Tariff Areas (DTA) serve domestic markets under standard customs duties. Reliance claims “fully segregated” crude processing between its SEZ export refinery and DTA domestic refinery, asserting Russian crude flows only to DTA post-November 20, 2025.

With 58.9% of all sanctioned product exports originating from this single refinery complex, any breakdown in Reliance’s segregation protocols would expose a major EU exporter and its related business parties to sanctions. The concentration risk is unprecedented: no other refinery globally commands comparable market share in this sanctions-exposed product category.

Other Indian exporters contributed minimally: Vadinar (Nayara Energy) exported 940K barrels (0.9%), while New Mangalore and other state refiners combined for 1.2 million barrels. Post-EU sanctions designation in July 2025, Nayara redirected exports from Europe to Middle East, Turkey, Taiwan, and Brazil, effectively exiting EU markets.

2.3 Turkey: STAR Refinery Phase-Out

Turkey exported 37 million barrels (37.0% of total), with 100% concentration at Aliaga port (STAR Refinery and Tupras Izmit). Unlike India’s export-focused model, Turkey’s Mediterranean proximity enables shorter voyage times to Greek, Italian, and Romanian ports, reflected in the 43.8% share of exports destined for Mediterranean EU markets.

STAR Refinery and Tupras announced phase-outs of Russian crude post-October 2025 sanctions on Rosneft and Lukoil, with observable volume declines in Q4 2025. Turkey’s product mix differed from India’s: higher shares of gasoline/blending components (22.8% vs. India’s trace amounts) and fuel oil (9.1% vs. zero), reflecting different refinery configurations optimized for Mediterranean market demand.

Given the announced phase-out and single-refinery concentration, Turkey represents a declining but concentrated risk through January 21, 2026 as existing refined product inventory clears.

2.4 China: Minimal EU Exposure

China exported only 1.8 million barrels to EU markets throughout 2025 (1.8% of total), consisting entirely of jet fuel/kerosene from Qingdao terminals. The data demonstrates that Chinese refineries processing Russian crude – whether state-owned majors or independent teapots, export predominantly to Asian markets.

Qingdao’s 882K barrels and other minor Chinese ports account for less than 2% of total Russian-derived product flows to the EU, suggesting Chinese refining capacity serves domestic consumption and regional Asian demand rather than transatlantic export arbitrage.

2.5 Export Routes: Direct Shipments Dominate

95.2% of product exports (144.2 million barrels) occurred via direct shipments from refineries to EU discharge ports, with only 4.8% (7.3 million barrels) involving Ship-to-Ship (STS) transfers at intermediate hubs. This overwhelmingly direct routing pattern contrasts sharply with crude import flows, where STS plays a larger role in obscuring vessel and cargo origins. Possibly, post January 21, 2025 sanctions STS hubs will become more dominant as a sanctions evasion tactic.

STS Transfers

While STS operations serve legitimate operational purposes – such as distributing large-volume cargo from large vessels into smaller Aframax or MR tankers for shallow-draft port access – they present regulatory vulnerabilities for sanctions enforcement. STS zones operate outside formal port jurisdiction, lack customs oversight during transfer, and enable covert “semi-dark-STS” operations where a sanctioned vessel transfers cargo to a compliant vessel with AIS systems disabled, obscuring origin and evading traceability requirements.

2.6 Temporal Patterns: October Pre-Sanctions Surge

Monthly export volumes reveal clear pre-sanctions stockpiling behavior by EU buyers. October 2025 recorded the year’s highest monthly exports at 11.6 million barrels – a 45% surge above the monthly average of 8.0 million barrels. This spike occurred immediately following the EU’s October 16, 2025 publication of detailed guidance on Article 3ma implementation, signaling imminent enforcement.

Quarterly  breakdown:

• Q1 2025: 8.5M bbl average (Jan-Mar).
• Q2 2025: 10.5M bbl average (Apr-Jun).
• Q3 2025: 7.8M bbl average (Jul-Sep).
• October: 11.6M bbl (peak).

The October surge indicates EU importers frontloaded purchases ahead of the January 21, 2026 ban, maximizing inventory of soon-to-be-prohibited Russian-derived diesel and gasoline. This pre-compliance stockpiling mirrors patterns observed in prior sanctions implementation cycles, where market participants rush to complete transactions under expiring regulatory windows.

2.7 Tanker Fleet: Pre-Sanctions Baseline

Windward Maritime Compliance tracked 329 tanker vessels conducting exports from Russian-crude-processing refineries in India, China, and Turkey to EU markets throughout 2025. This fleet exhibits markedly different risk characteristics than the crude tanker fleet analyzed in Section 1.

Fleet Characteristics

• Average age: 14 years (built 2011) vs. 16 years for crude fleet.
• Average DWT: 59,163 tons vs. 154,420 tons for crude fleet (Aframax/LR1 class vs. Suezmax/VLCC).
• Flag distribution: 75.1% flags of convenience (Liberia 77 vessels, Marshall Islands 59, Malta 53, Panama 42).

Windward Sanctions Risk Profile

• High Risk: 101 vessels (30.7%).
• Medium Risk: 33 vessels (10.0%).
• Low Risk: 190 vessels (57.8%).
• Sanctioned: 5 vessels (1.5%).

The combined High+Medium risk proportion of 40.7% contrasts sharply with the crude fleet’s 86.9% High+Sanctioned rate, suggesting product exports utilize more compliant commercial shipping rather than dedicated shadow fleet infrastructure. Only 1.5% of product tankers are sanctioned (5 vessels) compared to 33.8% of crude tankers (116 vessels) – a 22-fold difference in sanctions exposure.

Pre-Sanctions Intelligence Baseline

This fleet represents a critical pre-sanctions baseline for Windward’s algorithmic risk scoring. As the January 21, 2026 ban takes effect, Windward’s platform will begin tracking behavioral changes indicating compliance risk which are currently compliant. 

The current low-risk profile will serve as a comparative benchmark: any post-January 21 spike in High-Risk vessel activity, sanctioned vessel substitutions, or fleet age increases would signal sanctions evasion adaptation. Windward’s algorithms will recalibrate risk scores incorporating these post-ban behavioral patterns, enabling dynamic identification of emerging evasion networks as enforcement begins.

Section 3: Tracking the Russian Molecule

Windward enables customers to avoid sanctions by following the Russian molecule itself, from a sanctioned Russian crude lift to refined CN 2710 product moving through deceptive shipping activities. This case links three tankers and uses AIS‑based drafts, port calls at mapped port facilities connected to designated refineries, and cargo intelligence to maintain that chain of custody.

3.1 Sanctioned Crude: From Kozmino to Qingdao

The first vessel is an Aframax crude tanker under the fraudulent flag of Curacao, sanctioned by the UK and EU in May 2025 for its role in Russia’s oil trade. In early June, it calls Port Kozmino Crude Oil Terminal, Russia’s Far East ESPO export outlet, and loads around 770K barrels of ESPO blend crude before sailing for China.

AIS and cargo data show the tanker discharging that ESPO parcel into the Qingdao refining system (Yulong Petrochemical) between 9 and 11 July. Immediately after completing the port call on 11 July, the vessel reports a draft decrease from 14.0m to 8.5m, confirming that it had offloaded substantial crude cargo. This establishes a clear chain from a sanctioned shadow‑fleet hull lifting Russian crude to a specific refinery complex in Qingdao.

3.2 Refined Jet Fuel: From Qingdao to Malta STS

Within the same 8–11 July window, a newly built LR2 clean tanker under a Liberian flag of convenience calls at Qingdao. It loads jet fuel (CN 2710) at Huangdao Oil Terminal, Qingdao port, drawing on the refining system that has just received Russian ESPO. Draft data show a rise from 11.3m to 14.1m on 10 July, immediately after loading, consistent with a full LR2 cargo of refined product. The vessel is chartered by a major commodity trader and itself is not sanctioned; on paper it is a standard long‑haul clean tanker moving Chinese jet fuel to the Mediterranean.

From Qingdao it sails west through Suez and into the central Mediterranean. On 13–14 August, Windward’s AIS analysis shows the LR2 conducting a prolonged Ship‑to‑Ship transfer in the Malta STS area with a second, Bahamian‑flag products tanker. Following this STS, on 14 August the LR2’s reported draft drops from 13.1m to 10.8m, signalling a significant cargo discharge into the receiving tanker. The LR2 then moves on, while the Russian‑linked molecule continues its journey on the new hull.

3.3 The Russian Molecule Arrives to Europe

The receiving vessel is an oil products tanker under a Bahamian flag of convenience. After the STS-Meeting in Malta, the vessel updated its draft from 7.5m to 10.4 indicating the jet-fuel was loaded. The vessel visited several countries including one port-call in Egypt after which it reported a slight draft decline to 10m.

The tanker then proceeds to Civitavecchia, Italy, which hosts a major jet fuel storage complex managed by the Ludoil Group, allowing tankers to discharge aviation fuel, mainly to supply Rome’s Fiumicino Airport through a dedicated pipeline. After its port call on 3–5 September, the draft drops again from 10.0m to 7.5m, indicating full discharge of the cargo loaded in Malta. Windward’s RSI (Remote Sensing Intelligence) capabilities matched the AIS transmission of the vessel with a satellite image showing the vessel moored in the port’s dedicated Single Point Mooring (SPM) offloading product. Taken together, the evidence indicates that the product containing Russian molecules is ultimately landed in Italy – cargo that would be banned in the EU under Article 3ma once the sanctions take effect on 21 January 2026.

Report Summary

This report examines the sanctions risks associated with Russian crude imports and refined product exports from India, China, and Turkey to the EU. In 2025, these three countries processed 1.17 billion barrels of Russian crude, which is primarily refined into products destined for the EU. India dominates imports, followed by China and Turkey, with significant compliance risks due to the concentration of Russian crude in key refineries like Reliance Jamnagar in India. 

Exports of refined products to the EU reached 100 million barrels, with India leading, followed by Turkey and China. A surge in exports in October 2025 indicates stockpiling behavior before the January 2026 sanctions deadline. Windward’s vessel tracking identifies high-risk ships and potential sanctions evasion tactics, including the use of flags of convenience and complex ship-to-ship transfers. 

The report concludes that monitoring refined product exports, vessel movements, and compliance risks is critical to identifying and preventing sanctions evasion.

DISCLAIMER

The results presented in this report were produced by the Windward System. While the Windward System is proven to yield outstanding and reliable results, these contain by nature statements, and conclusions based (inter alia) on estimates, predictions, assumptions, and data which are subject to uncertainties beyond the control of the supplier and therefore might possibly include inaccuracies. The user is therefore encouraged to examine the results and consider additional means to augment conclusions in case any action is taken.