What a clear contrast we are witnessing this week regarding the U.S., Europe, and UK’s differing approaches to sanctions.
On the third anniversary of Russia’s Ukraine invasion, the U.S. chose to sanction the dark fleet…of Iran?
“Iran continues to rely on a shadowy network of vessels, shippers, and brokers to facilitate its oil sales and fund its destabilizing activities,” said Secretary of the Treasury Scott Bessent. “The United States will use all our available tools to target all aspects of Iran’s oil supply chain, and anyone who deals in Iranian oil exposes themselves to significant sanctions risk.”
Not sanctioning Russia was a major departure from the Biden administration – the two previous anniversaries were marked by new U.S. sanctions announcements regarding Russia. President Trump is trying to negotiate a peace deal with President Putin and the United States joined Russia to vote against a UN General Assembly resolution condemning Russia’s war in a huge shift in U.S. policy.
Europe and the UK Stay the Path
Meanwhile, the European Union (EU) ramped up pressure with a tough sanctions package on the third anniversary of the Russia-Ukraine war:
- 74 new shadow fleet vessels blacklisted – bringing the total to 153
- Ban on Russian primary aluminum imports – with a temporary quota for transition
- Expanded financial restrictions – targeting banks and crypto providers tied to sanction evasion
- Infrastructure crackdown – bans on major Russian ports and airports
The EU’s 16th package includes 83 additional listings, including 48 individuals and 35 entities, such as those supporting the Russian military complex, active in sanctions circumvention, Russian crypto assets exchanges, and the maritime sector.
The UK also announced over 100 new sanctions directly targeting those who continue to aid the invasion on the third anniversary.
Targets include:
- Producers and suppliers of machine tools, electronics and dual-use goods for Russia’s military, including microprocessors used in weapons systems.
- North Korean Defence Minister No Kwang Chol and other North Korean generals and senior officials
- 13 Russian targets
- For the first time, foreign financial institutions supporting Russia’s war efforts
We now have various sanctioning bodies with vastly differing views and aims.
What We are Seeing in the Sea
European Union (EU)
Our Maritime AI™ platform produced insights that show that European leaders might have already stopped relying on OFAC due to anticipation of President Trump’s shift, along with some other interesting insights:
- The newly sanctioned vessels are all tankers – most are crude oil tankers
- Top flags: Panama, Djibouti, and Barbados. Our Q4 risk report highlights how the Barbados flag registry, with little to no prior activity before November 2023, gained significant popularity in 2024.
- +190 vessels registered under Barbados in 2024, with 67% joining during H2 of 2024
- 20% of the vessels that switched to the Barbados flag in 2024 were owned by Sovcomflot and all of them previously flew the Gabon flag
- Currently there are +570 vessels sailing under the flag of Barbados – only 8% are sanctioned
- 59 of the 74 new shadow fleet vessels were already previously sanctioned by OFAC – so there are only 15 newly-sanctioned vessels
- This might show Europe not relying on OFAC, possibly anticipating that Trump will decide to remove sanctions from Russia
- The rest were flagged by Windward as risky prior to their designation
UK
Perhaps unsurprisingly, many of the OFSI-sanctioned vessels also fly Panama and Barbados flags, respectively
- Top flags: Panama, Gabon, and Barbados
- All flagged vessels were flagged as risky in Windward’s system due to their Russian affiliation – Windward customers don’t have to wait for these official announcements!
- The newly sanctioned vessels are all tankers – mostly crude and oil products
How to Prepare for the EU and UK Packages
Here are four best practices:
- Screen vessels and counterparties in real-time – with 74 additional vessels now on the radar, and different vessels being designated by different regulators, it’s critical to have AI-powered, advanced screening mechanisms in place to identify high-risk ships before engaging in transactions.
- Strengthen compliance workflows – automating due diligence processes and leveraging AI-driven insights can reduce the risk of unintentional violations.
- Stay ahead of regulatory changes – sanctions evolve rapidly. Automatic policy updates are essential for staying compliant and avoiding last-minute operational disruptions.
- Monitor supply chain exposure – with Russian aluminum imports restricted, traders and manufacturers must reassess sourcing strategies to avoid supply bottlenecks.
- Conduct due diligence – organizations need to know which financial institutions they are doing business with
How to Handle the Widening U.S.-Europe Sanctions Gap
With U.S, EU, and UK sanctions dramatically diverging, traders and shippers must be more agile than ever. Companies operating globally cannot rely on a one-size-fits-all approach to compliance. The chasm between U.S. and European policies means that a transaction deemed permissible under one regime may be high-risk under another.
Rigid compliance processes that rely on static lists or outdated monitoring methods won’t cut it. Businesses must build flexibility into their compliance strategies to react swiftly to evolving regulatory landscapes. This requires real-time risk assessment, automated updates, and the ability to navigate shifting policies across multiple jurisdictions.
Windward enables businesses to bridge the U.S.-EU sanctions divide by providing:
🚢 AI-powered, real-time screening – identify high-risk vessels, entities, and transactions instantly, ensuring compliance with the latest sanctioning body updates.
📡 Dynamic risk intelligence – track sanction changes as they happen and understand their operational impact without waiting for manual updates.
🔍 Behavioral-based vessel risk assessment – go beyond static watchlists and detect deceptive shipping practices used for sanctions evasion, including illicit transshipments and suspicious ownership changes.
📊 Customizable compliance workflows – tailor risk parameters based on jurisdictional requirements to ensure both U.S. and EU regulatory compliance.
Our partnership with LSEG integrated select LSEG’s World-Check services into our Maritime AI™ platform, providing users with comprehensive compliance and risk management solutions beyond the maritime domain. This creates a unique offering to empower Windward’s customers to stay ahead of emerging sanctions globally, with one unified system for sanctions screening.
As geopolitical shifts continue to shape the sanctions landscape, the ability to respond quickly isn’t just an advantage – it’s a necessity. Windward helps businesses stay compliant, avoid costly missteps, and keep operations running smoothly amid regulatory uncertainty.
See How You Can Stay Ahead
