Compliance in a Shifting Sanctions Landscape: What’s New in 2025

In the first quarter of 2025, sanctions enforcement has taken centre stage in the oil trading world. The regulatory landscape has grown more aggressive, with authorities in the US, UK, and EU signalling that compliance lapses—intentional or otherwise—will not be tolerated.

The US has ramped up its use of secondary sanctions, with a sharper focus on oil flows connected to sanctioned jurisdictions. Executive Order 14245 introduced in March threatens trade retaliation against countries indirectly supporting sanctioned energy markets. For trading companies, this adds a new layer of exposure—extending risk well beyond direct transactions.

At sea, the increasing reliance on so-called “shadow fleets” has further complicated operations. The industry has seen a rise in ship-to-ship transfers in international waters to obscure cargo origin, often involving older vessels with unclear ownership and expired insurance. These movements are under growing scrutiny. In April, the US Treasury updated its maritime advisory on sanctions evasion tactics, cautioning companies against indirect facilitation of prohibited trades.  

Meanwhile, the UK and EU have also widened their enforcement scope. Recent measures included new designations of individuals, companies, and vessels linked to the movement of sanctioned oil. These additions have already prompted many shipowners and insurers to reassess exposure, particularly where vessels may have interacted with restricted cargoes in the past.

The message to the trading community is clear: compliance can no longer be reactive. Firms are expected to conduct thorough due diligence across the supply chain, including vessel tracking, counterparty risk assessments, and documentation review. With enforcement actions becoming more frequent and fines increasing, the cost of falling behind is growing.

The second half of 2025 is likely to bring more of the same—heightened vigilance from regulators and increased pressure on market participants to adapt. For oil traders, agility and robust internal controls are no longer optional—they are essential.

Sources:

“Executive Order 14245—Imposing Tariffs on Countries Importing Venezuelan Oil | the American Presidency Project.” Ucsb.edu, 2025, www.presidency.ucsb.edu/documents/executive-order-14245-imposing-tariffs-countries-importing-venezuelan-oil.

Liu, Siyi. “Russian Arctic Oil Exports to China Jump Helped by STS Transfers, Sources Say.” Reuters, 17 Apr. 2025, www.reuters.com/business/energy/exports-sanctioned-russian-arctic-oil-china-set-rise-april-sources-say-2025-04-17/.

Psaledakis, Daphne. “US Issues New Sanctions Targeting Chinese Importers of Iranian Oil.” Reuters, 16 Apr. 2025, www.reuters.com/world/us-issues-new-sanctions-targeting-chinese-importers-iranian-oil-2025-04-16/.