How can you quantify pressure? For commodity traders, who operate under a unique blend of complex sanctions, regulatory scrutiny, and wholly unpredictable geopolitics, it’s clear the pressure is on. And Q3 2025 data from Windward, provider of maritime risk and intelligence solutions, can demonstrate how this pressure has accelerated.

In particular, the evolution of sanction enforcement in 2025 thus far has seen the traditionally static policy tool transform into a dynamic force, which is shaping trader behaviours and directing supply chains like never before. 

Tighter controls, faster evasions

The first half of 2025 marked a turning point in sanctions enforcement and evasive activity across the maritime trade ecosystem.

The year was opened by a decisive ramp-up of sanctions pressures: the first few months of 2025 saw the highest number of newly sanctioned vessels in three years. 88% of these vessels were tankers, reflecting regulators’ ongoing focus on energy-related trade. 

Sanctions enforcement was also at the forefront of regulators’ minds: the EU’s 16th sanctions package, passed in February, imposed new restrictions on entities and individuals involved in sanctions evasion, added 73 shadow fleet vessels to the EU blacklist, and introduced a ban on Russian primary aluminium imports. Maritime companies’ designations also rose, with 70% of newly sanctioned firms located in five jurisdictions – Hong Kong, the Seychelles, China, Russia, and the Marshall Islands – which are commonly used to obscure real ownership structures and bypass sanctions. 

Sanctions pressures only kept rising. The EU’s next sanctions package, passed in May, sanctioned 342 ships in total, 97% of which were tankers and many of which were flagged in third countries but used for deceptive trade supporting Russia’s wartime economy. The measures expanded to the entire shadow fleet ecosystem by targeting flag registries, financial institutions, and port operators: the infrastructure enabling sanctions evasion. However, commitment diverged: in March, the U.S. vetoed a G7 proposal to target the shadow fleet more directly, signalling a split in Western coordination. 

In the face of increased scrutiny, would-be sanctions evaders turned to behavioural deceptive shipping practices (DSPs), relying on AIS gaps, GPS jamming, and the use of fraudulent flags to evade detection. By mid-2025, compliance teams were overwhelmed with both volume and velocity. The behaviour of bad actors was evolving faster than most systems could track, creating blind spots, delays, and rising operational risks. 

Precision above all  

In the second half of the year, regulators moved from sweeping mandates to targeted enforcement, honing in on key actors and enablers of sanctions circumvention. At the same time, while the rate of new vessel sanctions slowed, the total number of vessels sanctioned by the EU, UK, and US surpassed 1,000 for the first time ever, proving the sanctions that have been fundamentally transforming the maritime shipping landscape since 2023 are here to stay.  

The EU and UK took the lead, sanctioning a total of 311 Russian-linked vessels in Q3 2025, for a cumulative total of 540 and 480, respectively.  On the other side of the Atlantic, the US issued no new Russia-related maritime sanctions for the second consecutive quarter, instead launching its largest Iran-related designation since 2018. These sanctions target over 60 vessels, including a fleet of Iran-calling containerships, signalling a shift beyond oil and gas enforcement.

Despite targeted enforcement, deceptive shipping practices continued to rise. Like the number of sanctioned ships, the number of falsely flagged vessels also surpassed 1,000 for the first time, doubling in just nine months. The number of newly sanctioned companies also doubled in just three months, with almost 60% based in the UAE and the Marshall Islands. 

These trends reflect a continued shift – for both regulators and bad actors – beyond vessel behaviour into ownership, financial, and regulatory evasion infrastructures. Taken together, this is ushering in a new phase in maritime sanctions. Sanctions in 2026 and beyond are more likely to be increasingly jurisdiction-specific, enforcement-driven, and aimed at closing the operational gaps enabling circumvention.

The future of sanctions

As the year draws to a close, it has become clear that maritime sanctions are reshaping how oil, gas, metals, and critical raw materials are traded every day. Unlike the uniform measures seen at the start of the Russia-Ukraine conflict, sanctions enforcement is now unpredictable. With the U.S. pulling back on Russia-related vessel sanctions at the same time as the EU and UK accelerate designations, organisations are having to navigate inconsistent, ever-changing rules. What’s legal in one jurisdiction could be high risk in another, and trade finance teams must interpret not just regulations, but intentions.

As the playing field expands, so must compliance.  Sanctions now reach deep into the commodity value chain, hitting shipowners, operators, flag registries, insurers, port agents, and even financing entities. This means that for the first time ever, KYC and KYV are converging. Every counterparty, not just the vessel, must be screened, verified, and monitored across the entire transaction lifecycle in order to adapt to the new requirements.

As a result of these changes, supply chain disruptions are already increasing and are likely to continue doing so. Ship-to-ship (STS) transfers of sanctioned oil are clustering in new jurisdictions, Iranian containerships are being blacklisted, Russian LPG and aluminium trades are under regulatory review, and  AIS gaps and location (GNSS) manipulation are obscuring critical flows. In the face of these disruptions, commodity traders and banks are facing delays and being forced to make de-risking decisions driven by incomplete or outdated data.

While decision-making becomes harder, the stakes are only getting higher. Missed red flags can stall trades, trigger compliance reviews, or block payments altogether. At the same time, over-screening and irrelevant alerts are draining resources, delaying transactions, frustrating clients, and putting pressure on already overloaded compliance and credit teams.

To succeed in the new era of sanctions, organisations will need more than list-matching or static screening. The new era of sanctions will require global players to step up their game and look towards more dynamic monitoring, like behavioural intelligence that can spot evasion tactics before the risk hits the ledger.

For example, Windward’s Maritime AI™ enables real-time trade decisioning by combining vessel behaviour analytics, ownership and registry transparency, counterparty risk scoring, and document validation and DSP detection.

This helps commodity traders know which deal will get stuck before it does and plan around delays.  By having the right information in real time, trade finance teams can issue credit with confidence and defend their decisions when challenged; financial institutions can operate faster, with fewer false positives and lower exposure.

—

Going into 2026 and beyond, sanctions enforcement is shaping how commodities move: who carries them, where they load, and how they’re financed. The next quarter-century of maritime trade will be shaped by sanctions in every aspect, from trade routes to financing flows. While the jurisdictions, scope, and enforcement may change, shaped by geopolitical developments and the global economic situation, sanctions have cemented their role as a key driver of global trade: organisations will have no choice but to keep up.