EU and Global Regulators Step Up Sanctions Enforcement against Russian Shadow Fleet

EU General Court Affirms Sanctions Designations

On November 26th 2025, the European Union General Court issued two important judgments that strengthened the legal basis of EU sanctions enforcement. They excluded challenges brought against Musa Yusopovich Bazhaev and SBK Art OOO challenging their listings on EU sanctions registers; these rulings provide vital confirmation of EU's sanctions architecture as well as support for restrictive measures targeting Russian actors.

The dismissals demonstrate the EU's dedication to upholding comprehensive sanctions regimes despite legal challenges from individuals or entities designated for sanctions, providing regulatory certainty for member states and enforcement agencies across Europe implementing sanctions across their regions.

OLAF and Europol Launch Sanctions Evasion Task Force

On November 17-18, 2025, OLAF and Europol intensified their cooperation to counter sanctions circumvention in Russia and Belarus. At an exclusive meeting held between November 17-18th 2025, both organizations convened jointly to examine emerging trends of sanctions evasion while strengthening coordination enforcement action - an unprecedented institutional response to growing sophistication of sanctions avoidance networks.

OLAF and Europol's partnership marks an evolution toward more integrated European enforcement mechanisms. By combining anti-fraud expertise with law enforcement capabilities, both agencies seek to identify and dismantle complex networks facilitating sanctions violations across multiple jurisdictions.

Ukraine Sanctions 56 Vessels for Illegal Port Operations

On November 25th 2025, President Volodymyr Zelenskyy issued a decree imposing sanctions on 56 maritime vessels that illegally entered Ukrainian ports temporarily occupied by Russia between 2022-2025 for exporting Ukrainian food products in violation of Ukrainian law. Many of the targeted vessels had already been hit with sanctions from European Union countries such as USA or Switzerland.

Zelenskyy's administration noted that individuals conducting these prohibited operations paid taxes into Russia's state budget and directly funded Moscow's military capabilities; thus demonstrating Ukraine's efforts to close legal gaps and avoid third-party complicity in sanctions evasion.

Canada Expands Shadow Fleet Sanctions

On November 12, 2025, Canada issued comprehensive sanctions targeting Russian drone manufacturers and 100 vessels from Russia's shadow fleet. This action aligns with international efforts to disrupt Russia's circumvention networks and represents a substantial expansion of Canadian maritime sanctions enforcement.

Canadian designations follow in the footsteps of similar actions taken by other Western nations to exert coordinated pressure on Russia's shadow fleet infrastructure allowing it to transport sanctioned oil and petroleum products despite international sanctions.

UK National Crime Agency Issues an Amber Alert Regarding Maritime Sanctions Evasion

The UK National Crime Agency recently issued an amber alert to help maritime and financial institutions identify and prevent sanctions evasion for commodities, specifically targeting networks supporting sanctioned regimes like North Korea, Iran and Russia. It built upon previous guidance issued in July 2025 regarding Russian shadow fleet sanctions avoidance networks.

The alert provided maritime and financial sector businesses with specific sanctions evasion typologies and warning flags to incorporate into their compliance frameworks and risk analyses in order to strengthen private sector participation in sanctions enforcement. This proactive guidance represents an effort to promote greater private sector participation.