On 10 January 2025 the United States implemented its most extensive sanctions on Russia to date, targeting 183 vessels, 41 individuals, and 75 companies. These measures mark an unprecedented escalation in efforts to weaken Russia’s economic base, particularly its lucrative oil industry.
The Biden administration has positioned these sanctions as a pivotal move to undercut Russia’s financial ability to sustain its war in Ukraine.
Sanctioned vessels largely belong to a dark fleet flagged under jurisdictions such as Panama, Vietnam, Gabon, Antigua and Barbuda, Sierra Leone, Barbados, the Cook Islands, Liberia, San Marino, and Belize. A complete list of sanctioned vessels can be found here.
The effects of these sanctions are already becoming apparent. For example, India, a significant importer of seaborne Russian oil, has announced that it will ban sanctioned vessels from entering its ports once the transitional wind-down period ends on 12 March 2025. (This wind-down period permits limited transactions related to Russian energy, helping countries and companies gradually reduce their reliance on Russian energy.)
Key Measures
The U.S. targeting authorities imposed sanctions on ‘any persons determined to operate or have operated in Russia’s energy sector,’ leading to actions against:
- Major oil producers such as Gazprom Neft and Surgutneftegas: This marks the most direct and assertive action taken by the U.S. or any Western power to date. Combined, these companies transported around 970,000 barrels of oil per day in 2024.
- Oil Tankers: Sanctions have been imposed on 160 individual oil tankers, which represents around 10% of the global tanker fleet, doubling the number of vessels targeted by the U.S., UK, and EU combined. While some of these ships were already sanctioned by London and Brussels, it is suggested that U.S. measures have so far been notably more disruptive. Before Friday, OFAC had sanctioned 39 tankers involved in transporting Russian petroleum since October 2023. Ship-tracking data shows that 33 of these vessels have not carried any cargo since being sanctioned.
- Sanctions on Support Networks and Third-Party Enablers:These latest sanctions imposed by the United States underscore the U.S.’s readiness to target businesses in consuming nations that aid the Russian oil trade, emphasising the need for diligent compliance practices to avoid secondary sanctions.
- Traders: Opaque traders involved in Russia’s oil trade have been sanctioned. Such traders often operate in high-risk jurisdictions and attempt to conceal their activities and ties to Russia.
- Ship Insurers: The U.S. has introduced sanctions on major Russian insurers, Ingosstrakh and Alfastrakhovanie.
- Oil Services: New sanctions require American petroleum service companies to halt operations in Russia by 27 February 2025. This won’t have an immediate impact on Russia’s oil production, as most services are handled by domestic companies; however, it could affect long-term projects that depend on advanced foreign technologies. This may lead to slowdowns in Russian oil production, particularly in Arctic reserves and offshore fields, due to the lack of modern technology.
Unlock Real-Time Vessel Tracking and Compliance with Pole Star Global
Vessels targeted by OFAC have begun using deceptive tactics, such as changing names, to avoid detection and continue illicit activities. As such, you must act quickly to identify whether you are exposed to these vessels and unintentionally engaging with such entities.
Engaging with vessels linked to the Dark Fleet poses significant compliance and reputational risks. Many of these vessels are eventually sanctioned, leaving businesses exposed to regulatory scrutiny and financial loss.
Pole Star Global’s PurpleTRAC, a tool actively used by OFAC, is specifically designed to identify vessels involved in illicit activities. With ongoing upgrades, PurpleTRAC will ensure you stay one step ahead of emerging compliance risks by offering:
- Instant alerts when screening newly sanctioned vessels.
- Continuous vessel tracking and monitoring, with automatic email alerts.
Mitigating Dark Fleet Risks with Deep Blue Intelligence (DBI)
Pole Star Global and Blackstone Compliance Service’s Deep Blue Intelligence (DBI) empowers you in staying ahead of compliance risks by:
- Proactive Risk Identification: DBI identifies high-risk Dark Fleet vessels months before they appear on sanctions lists, leveraging proprietary research from:
- Businesses and flag registries.
- Multiple vessel tracking and maritime data sources.
- Satellite imagery and Earth observation data.
- Proprietary DBI Watchlist: Gain access to the curated DBI watchlist, which includes vessels flagged as high-risk through extensive analysis and predictive indicators of illicit activity.
- Enhanced Due Diligence: Equip your compliance teams with actionable intelligence to avoid engaging with vessels exhibiting red flags, such as ownership concealment, deceptive practices, and irregular flagging patterns.
- Future-Proof Compliance: Reduce exposure to regulatory action by avoiding transactions or engagements with vessels likely to be designated by OFAC or other authorities in the future.
With DBI, you can navigate the complexities of maritime compliance with confidence, protecting your organisation from the financial and reputational fallout of inadvertent sanctions breaches.
To learn more or arrange a call with a team member, get in touch today.