Navigating the New Sanctions Reality: OFAC’s 2025 Maritime Advisory & EU’s 18th Sanctions Package

April and July 2025 brought two of the most consequential regulatory shifts in recent maritime history. First, OFAC’s latest maritime advisory redefines compliance expectations for U.S.-linked stakeholders. Then, the EU’s 18th sanctions package recalibrated oil trade flows and expanded enforcement well beyond Europe’s borders, including new restrictions on Russian-origin oil products refined in third countries.

If you operate, finance, insure, or service vessels, the message from regulators is clear: reactive compliance is no longer enough, and the scope of who’s responsible has widened.

OFAC 2025 Advisory: Behavioral Risk Takes Center Stage

In its latest maritime sanctions advisory, the U.S. Treasury’s Office of Foreign Assets Control (OFAC) has elevated behavioral risk to stand alongside entity-based risk as a primary compliance concern. This builds on its 2020 guidance, which first classified deceptive shipping practices like AIS manipulation, ship-to-ship (STS) transfers, and false flagging as core red flags.

What’s different in 2025 isn’t the list of risks – it’s the expectation of proactive detection and investigation. OFAC is no longer satisfied with reactive screening, meaning that organizations are now expected to document how they identify and address high-risk behaviors before they escalate into violations.

Primary updates include:

• Behavioral red flags carry equal weight with sanctioned entity matches in enforcement actions
• Documentation is mandatory for legitimate AIS disablement and other operational anomalies
• Heightened scrutiny on repeated STS transfers involving high-risk regions or actors
• Evidence-based investigations must be integrated into due diligence workflows, not handled ad hoc

This shift reinforces that compliance is no longer just about who a vessel is – it’s about how it behaves over time. For maritime stakeholders, that means investing in systems that can detect patterns like location (GNSS) manipulation, identity laundering, and concealed port calls in near real time.

EU’s 18th Sanctions Package: A New Layer of Complexity

The European Union’s latest sanctions on Russia introduce some of the most sweeping maritime compliance measures to date, directly targeting flag registries, expanding the dark fleet list, and tightening enforcement on oil price caps.

Key shifts include:

• Direct targeting of flag registries: Gabon and Comoros registries sanctioned for enabling opaque and high-risk Russian oil transport, with over 130 flagged vessels already under Western sanctions
• Dark fleet expansion: 105 new tankers banned from EU ports, all flagged by Windward as high-risk before designation
• Dynamic price cap mechanism: new $47.60/bbl cap for Russian crude starting September 3, 2025, revised every six months
• Ban on refined products from Russian crude: effective January 21, 2026, even if processed in third countries
• Crackdown on non-EU “enablers”: secondary sanctions-style measures on oil traders, shippers, and service providers in jurisdictions such as the UAE, India, and Singapore

These changes mark the EU’s most aggressive stance yet, widening its compliance net to include not just vessels and owners, but the commercial ecosystem that sustains sanctions evasion.

The Russian-Origin Refined Products Challenge

One of the most complex changes in the EU’s 18th package is the upcoming January 2026 ban on refined petroleum products made from Russian crude, even when processed in third countries like India, China, or Turkey. For European importers, this creates new documentation and verification requirements and a fair amount of confusion. 

The key question many operators are asking is: how can you prove a shipment of refined products doesn’t trace back to Russian-origin crude? This rule forces companies to look not just at the vessel that arrives at an EU port, but at the refinery where its cargo originated, and the fleet behavior leading up to that point. Without tools to map the supply chain, this quickly becomes unmanageable. 

OFAC vs. EU: Navigating Two Powerful Compliance Shifts

With the U.S. and EU both introducing significant maritime measures in 2025, understanding where they align and where they diverge is critical.

While OFAC’s latest advisory pushes behavioral risk monitoring to the forefront, the EU’s 18th sanctions package builds out a more aggressive trade and registry enforcement regime. Together, they set a new global baseline for what regulators expect from maritime stakeholders, regardless of flag, route, or operational geography.

Put side by side, the differences are striking – but so are the overlaps. Knowing where they align (and where they don’t) can help you stay one step ahead instead of scrambling to catch up.

For maritime operators, these frameworks aren’t competing – they’re cumulative. Compliance programs now need to detect, investigate, and document behavioral anomalies and account for the EU’s expanding sanctions net. Those who can operationalize both will be best positioned to avoid penalties, maintain market access, and protect their reputations in a volatile regulatory landscape.

How Windward Helps You Stay Ahead

With both OFAC and the EU raising the bar for maritime compliance, the challenge isn’t just knowing the rules – it’s proving you can meet them. Windward’s Maritime AI™ brings together behavioral analytics, global sanctions intelligence, and real-time risk alerts so you can:

• Detect deceptive shipping practices like AIS manipulation, identity laundering, and high-risk ship-to-ship transfers before they escalate
• Flag sanctioned vessels, owners, and registries even before public designation
• Automate documentation to meet regulator demands for legitimate AIS gaps and operational anomalies
• Map Russian crude supply chains and flag high risk refineries in third countries to identify refined products that may breach the EU’s 2026 ban
• Verify documentation, such as Bills of Lading and Certificates of Origin, against actual vessel behavior and refinery data 

By combining entity-based screening with continuous behavioral monitoring, Windward enables organizations to comply with both U.S. and EU requirements in a single, unified workflow.

The Bottom Line

OFAC and the EU may have different playbooks, but the signal is the same: compliance needs to be proactive, documented, and global in scope. For many operators, especially those with vessels, partners, or cargo touching both U.S. and European jurisdictions, that means meeting the requirements of both regimes at once. The operators that can integrate these expectations into daily decision-making won’t just avoid penalties – they’ll move with more confidence in an increasingly complex trade environment.