Sanctions SOS

Serbia’s oil refinery NIS is preparing to shut down after the US declined to extend an operating licence, raising concerns over the country’s fuel security and broader economic stability. The decision, communicated to Serbia last week, means the firm, majority-owned by Russia's Gazprom Neft (44.9%) and Gazprom (11.3%), must stop operations. President Vucic confirmed this week that the US rejected Serbia’s request for a sanctions waiver, which would've allowed continued oil supply while Russian owners negotiate a sale of their stake. NIS has been under US sanctions since 9 October, following earlier temporary waivers. Those were intended to give Serbia time to remove Russian ownership. Despite several extensions, the deadline passed with no divestment. Serbia formally sought another waiver on 19 November, which would have allowed the refinery to restart limited production in mid-December. The US declined, thus requiring a full shutdown of operations. Vucic warned that Serbia’s fuel supply chain is now extremely exposed, particularly as secondary sanctions risk extends to the National Bank of Serbia and commercial banks if they transact with NIS. While that risk exists, Vucic has confirmed that payments transactions with NIS will continue until next Monday to allow the firm to pay workers and make final payments. Vucic insisted current supplies of diesel, gasoline and kerosene are sufficient until late January, though transport costs will rise because fuel must be moved through alternative import locations. Fuel derivatives will continue to be supplied nationwide, except through stations owned by NIS. This situation leads into Serbia's growing dependence on imports, for example from Hungary's MOL. However, analysts warn that national refinery outages increase the risk of shortages in 2026. Vucic stated that Russian shareholders have 50 days to divest their majority stake. If they fail to do so, it was stated that the government of Serbia may step in and make an offer to buy them out. Potential buyers include MOL and investors from the UAE, but no formal negotiations have been announced. #serbia #NIS #US #Russia #sanctions #oilandgas #economicsecurity

It’s been an incredibly rewarding training year for us at Sanctions SOS. Why? 🔹132 professionals trained across private/public sectors 🔹100% trainee satisfaction rate 🔹Expansion into 3 specialist training areas: sanctions compliance; trade sanctions & export controls; sanctions investigations & combatting evasion 🔹4 Manchester sessions, supporting our local compliance community 🔹Refined our signature scenario-based approach, bringing sanctions theory to life in every session 💜 As we deliver our final Sanctions Compliance session of 2025 today, we'd like to deeply thank everyone who joined us this year - your support and trust means the world to a small business like ours. Looking ahead: our first 2026 session, Sanctions Investigations & Combatting Evasion, returns on 8 January in London due to popular demand. With only 2 spots left, book soon to start the new year sanctions-strong. Drop us an email at enquiries@sanctionssos.com to reserve your spot. #sanctions #training #compliance #investigations #smallbusiness #2025

Last week, 24 November, Dutch prosecutors opened criminal proceedings against shipbuilder Damen Shipyards, one of the Netherlands’ most important defence companies, over alleged breaches of EU Russia-related sanctions and a series of additional non-sanction offences. The Dutch Public Prosecution Service (OM) alleges that Damen violated the Dutch Sanctiewet in 2022 by exporting goods and technology to Russia, breaking EU restrictions. Prosecutors claim the company falsified customs declarations on 14 deck cranes shipped to Russia after the invasion of Ukraine, and that senior managers were directly involved. Damen denies wrongdoing, stating the June 2022 delivery involved a very limited number of civilian cranes supplied in full compliance with the sanctions regime in force at the time. The case is widely viewed as unprecedented, as it is the first prosecution of a major European defence contractor for sanctions evasion. Damen builds naval vessels for the Netherlands and NATO allies, and is considered a company of national strategic importance. Damen has also been charged with bribery, forgery and money laundering, based on a multi-year investigation dating back to 2015. The corruption allegations relate to sales campaigns in Africa, the Caribbean and Brazil, where Damen is accused of providing benefits to officials and concealing payments through accounting schemes. Beyond the 14 cranes, Dutch media reports that parts for the same Russian project continued to be supplied after 2022, via intermediaries in China and Turkey. Damen has rejected those findings, stating it has acted lawfully throughout. Since 2022, Dutch customs authorities have launched more than 100 investigations into breaches of Russia sanctions, and the financial crimes service (FIOD) has opened around 30 more. The Netherlands is currently among the EU’s most active jurisdictions for sanctions prosecutions. Prosecutors say companies have shifted from accidental breaches to increasingly sophisticated evasion methods, including the creation of fake websites designed solely to mislead investigators. They have also called for higher penalties for sanctions offences, noting that the current six-year maximum sentence for economic crimes limits the investigative tools they can deploy. A conviction could have significant operational consequences. If convicted of corruption, Damen could be excluded from government contracts for several years, a major risk for a firm that builds much of the country’s naval fleet. Individual executives face potential prison terms of up to four years. Damen maintains it acted transparently and within the law, says it is approaching the trial with confidence, and welcomes the chance to explain why it believes the accusations are unfounded. The next substantive hearings are expected in 2026. #damenshipyards #sanctionsevasion #enforcement #sanctiewet #netherlands

Today, 1 December, reporting by NK News revealed that a Chinese trader has been openly advertising the sale of more than 2000 used computers and graphics cards to North Korean buyers since 2024, a trade that sanctions specialists say likely breaches UN prohibitions on supplying industrial machinery to the DPRK. The seller, based in Guangdong and posting under the name Xiaoyang’s Trip to North Korea (小羊朝鲜之旅) on the Chinese social media app Xiaohongshu, has shared detailed accounts of shipments involving Dell and Lenovo devices (likely refurbished), including photos of computers being prepared for shipment and invoices showing unit values and quantities. One shipment described in July involved 400 Dell OptiPlex desktops worth approx $110,000, with branding removed prior to export according to pictures. According to his posts, hardware is purchased in southern China, moved to Dandong near the DPRK border, and then handed over by relatives able to communicate with Korean-speaking trading partners. The trader also shared contracts that appear to guarantee North Korean buyers a one-year warranty and stipulate that disputes can be handled in North Korean courts. This activity raises sanctions compliance concerns. Computers fall under HS Code 84, a category covered by UN Security Council Resolution 2397, which prohibits member states from supplying industrial machinery to North Korea, directly or indirectly. Experts warn that such hardware could be diverted to DPRK entities involved in cyber operations, intelligence gathering, or proliferation/WMD-linked research, including units under the Reconnaissance General Bureau. The trader’s posts also describe the practical challenges of moving goods into North Korea: rising transport costs when Chinese authorities tighten enforcement, payment delays from DPRK partners, and cash-flow strains when upstream suppliers demand full payment before shipment. He also noted recent North Korean demand for lower-end graphics cards, which he attributes to the country entering the PC and mobile era. This comes as the DPRK has expanded access to gaming for a small domestic elite, recently opening a new high-end gaming centre in the capital featuring ASUS machines and foreign titles, including Western military-themed games, despite heavy restrictions on outside culture. At the same time, the seller says North Korea prohibits computers containing South Korean components such as Samsung memory chips, reflecting the regime’s escalating efforts to remove South Korean cultural and technological influence. Foreign-made computers are known to circulate inside the DPRK despite longstanding sanctions. Dell machines have been spotted in multiple official institutions in recent years, highlighting continuing demand for foreign hardware and gaps in international export-control enforcement. #northkorea #dprk #china #unsanctions #exportcontrols

On 27 November, Lloyd's List published an article arguing that current sanctions on Russia’s 'shadow fleet' are not sufficiently disrupting oil flows or war financing. The article suggests that, while 100s of vessels and shipowners have been sanctioned, Russian oil continues to move widely, largely redirected to Asian markets. Rather than disrupting Russia's economy, the strategy has contributed to the growth of a parallel 'sanctioned economy' that operates alongside legitimate trade. Russia’s trade surplus peaking in 2024 is named as evidence that vesself-focused enforcement has not delivered the intended impact. A challenge identified is the lack of a clear definition of what the 'shadow fleet' actually is. Lloyd’s List proposes one of the most workable approaches to date, defining a shadow fleet tanker as a vessel that engages in deceptive shipping practices linked to sanctioned oil from Russia, Iran or Venezuela, is itself sanctioned for involvement in illicit oil trades, is connected to a sanctioned company, or participates in a cargo chain where deceptive practices occur at any point. The authors argue that without a clear definition that port officials and operators can apply in real time, enforcement will continue to fall short. As opposed to focusing mainly on ships, the article calls for a shift to ports as the pressure point. This makes logical sense: when vessels can't access ports, they can't trade. States already have the sovereign right to refuse port entry, but this power is underused in the context of shadow fleet activity. Targeting ports that routinely service these vessels could deter cooperation and raise the commercial/political cost of facilitating Russian oil exports. The authors also point to port compliance mechanisms like the ISPS Code as another enforcement route. Declaring ports that service shadow fleet vessels as non-compliant could restrict their access to insurance and global trade networks, discouraging legitimate operators from engaging with them. While maritime sanctions have become a popular tool, the article concludes that real impact will only come when enforcement moves closer to the port. This, the authors argue, is where compliance, regulation and accountability are more practical and enforceable. 🟣 Sanctions SOS perspective In line with this discussion, sanctions evasion moves beyond financial transactions: it is now increasingly about assessing risk in logistics, trade routes, and physical infrastructure. For businesses operating in shipping, commodities, insurance or trade, grasping port risk and shipment behaviour is now as important as screening counterparties. Sanctions SOS supports organisations in identifying exposure, assessing risk, and building compliance frameworks that adapt to emerging evasion tactics and changing regulatory expectations. 📩 Contact us today: enquiries@sanctionssos.com #russiasanctions #shadowfleet #maritimerisk #compliance

Who said that sanctions compliance has to be overwhelming? With the constant changes in regulation and geopolitical tensions, compliance profs are expected to constantly stay up to speed. Especially in the current environment, staying ahead of sanctions risks has never been more important, or challenging. But it doesn't have to be that way. Join us for our immersive Sanctions Compliance Training on 3 December in Manchester (UK) - the only training in the UK that brings sanctions to life by combining theory with a developing, realistic scenario. (full syllabus below) This training provides you with the skills you actually need in your day-to-day, instead of dry theory without application. What you’ll gain: - A clear understanding of the foundations of sanctions and global compliance frameworks - Practical tools to apply sanctions controls and licensing in real-world scenarios - Insight into common sanctions evasion tactics, including red flags in maritime activity and cryptocurrency risks - The ability to conduct effective horizon scanning and sanctions risk analysis - Enhanced skills in KYC, CDD, ownership structures and screening processes - Best practices shared through peer discussion in a focused small-group environment - Responding to evasion methods and emerging threats You'll also get: - Life-time access to all course materials - Networking opportunities - Breakfast/lunch/refreshments throughout the day - Certificate of attendance 📍 Location: Manchester, UK 📅 Date: 3 December ❗Only 2 places available due to small-group delivery 🎟️ All the above for only £375 pp (excl VAT) 📩 Email us today to secure one of the last places: enquiries@sanctionssos.com. #sanctions #training #sanctionscompliance #professionaldevelopment #Manchester

On 24 November, the US designated Venezuela’s alleged Cartel de los Soles as a Foreign Terrorist Organisation (FTO), expanding terrorism-related sanctions on a network the US claims is linked to President Maduro and senior military officials involved in large-scale drug trafficking into the US. The designation follows a July move by the Treasury Department to label the group a Specially Designated Global Terrorist (SDGT), freezing its US-linked assets and prohibiting dealings by US persons. The FTO listing represents the US's most severe terrorism classification, introducing expanded criminal liability for individuals/entities providing material support to the group. US officials allege the cartel operates in cooperation with the Venezuelan gang Tren de Aragua, itself previously designated an FTO, forming part of a wider narco-trafficking/corruption ecosystem that channels cocaine from Latin America into the US market. Venezuela’s government has rejected the designation as politically motivated, calling the cartel 'non-existent' and accusing the US of fabricating a pretext for intervention and regime change. While senior US defence officials suggested the move creates 'new options', sanctions experts and former Treasury officials stressed that FTO designation does not form a legal basis for military action. However, concerns have intensified as the US continues an aggressive maritime counter-narcotics campaign, including desdly strikes on suspected drug vessels in the Caribbean and Pacific. 🔹 Backstory: the US/Venezuela relationship The designation follows a sharp deterioration in bilateral relations under Trump’s second term. Since early 2025, the US has revoked oil concessions, imposed tariffs on buyers of Venezuelan crude, doubled rewards for Maduro’s arrest, and expanded military deployments around Venezuelan waters. The FAA has also issued hazard warnings for Venezuelan airspace, prompting airlines to suspend services. Venezuela insists the escalation reflects US ambitions to control Venezuela’s vast oil and mineral reserves. Analysts note that Cartel de los Soles is less an organised criminal cartel and more a systemic pattern of corruption linking elements of the military and political elite to trafficking networks. While Maduro is widely believed to be aware of military complicity, experts caution that publicly available evidence does not conclusively show direct operational control by the Venezuelan leadership. 🔹 Market/enforcement implications The FTO designation increases compliance risk for financial institutions, shipping firms and intermediaries operating in or through Venezuelan-linked trade corridors, particularly where dual-use logistics or informal value transfer systems intersect with illicit drug routes. Despite heightened pressure, Venezuelan sovereign bonds rose following the announcement, reflecting speculative investor interest amid geopolitical volatility. #US #Venezuela #sanctions #FTOdesignation #geopolitics

On 21 November, the UK’s National Crime Agency (NCA) issued an important update on Operation Destabilise, exposing a billion-dollar money laundering network operating across the UK and facilitating Russian sanctions evasion and payments linked to Russia’s military-industrial base. The investigation centres on two networks, Smart and TGR, which the NCA describes as professional laundering services converting proceeds from drugs, firearms and organised immigration crime into cryptocurrency. This cash-to-crypto pipeline has enabled sanctioned Russian actors to bypass UK, US and EU financial restrictions. 🔹 Kyrgyz bank acquisition to enable evasion The NCA revealed that Altair Holding SA, a UK-sanctioned entity linked to TGR, acquired a 75% stake in Keremet Bank in Kyrgyzstan in December 2024. The bank has reportedly been used to facilitate payments for Promsvyazbank, a Russian state-owned institution supporting companies tied to Russia’s military supply chain. The scheme also involves Ilan Shor and his sanctions-listed payment firm A7, which promoted the A7A5 ruble-backed stablecoin, suspected of being designed to circumvent sanctions and enable crossborder payments outside regulated channels. 🔹 UK-based criminal infrastructure The NCA identified laundering activity in at least 28 UK towns and cities, involving couriers collecting criminal cash and feeding it into international crypto networks. Since the operation began, enforcement outcomes include: - 128 arrests - Over £25m seized in the UK - $24m and €2.6m seized internationally - 45 additional arrests and £5.1m seized in the most recent phase 🔹 Key figures Smart is led by Ekaterina Zhdanova, alongside Nikita Krasnov and Khadzi-Murat Magomedov. TGR is headed by George Rossi, with Elena Chirkinyan and Andrejs Bradens as senior figures. All six were designated by OFAC in late 2024. Zhdanova is currently in pre-trial detention in France. Investigators also linked the networks to attempted funding of Russian intelligence-linked operations in Europe, including a UK-based espionage group later convicted of spying on Russia’s behalf. 🔹 Strategic implications The NCA describes this case as illustrating the direct connection between street-level crime, organised transnational laundering and state-sponsored activity. It highlights how crypto assets, offshore banking and weak jurisdictions continue to be exploited to undermine global sanctions frameworks. Authorities warn that while the operation has significantly disrupted these networks, similar structures remain active and adaptive, reinforcing the need for sustained vigilance across the financial and compliance sectors. #OperationDestabilise #UK #sanctionsevasion #financialcrime #Russiasanctions

Last week (12 Nov), OFAC designated the Democratic Karen Benevolent Army (DKBA), 4 of its senior leaders, and 3 associated companies for supporting large-scale cyber scam centres in Myanmar that US officials say have stolen billions of dollars from Americans. The move is part of a wider US campaign against Southeast Asia’s scam-centre economy, which relies heavily on human trafficking and has demonstrated extensive links to Chinese organised-crime groups. OFAC designated the DKBA and its commander-in-chief Saw Steel, adjutant general Saw Sein Win, chief of staff Saw San Aung, and senior figure Sai Kyaw Hla under EO 13694 (as amended) and EO 14014. OFAC also listed Trans Asia International Holding Group Thailand Co Ltd, Troth Star Co Ltd, and Thai national Chamu Sawang, accusing them of facilitating investment by Chinese criminal networks and helping armed groups build and operate scam compounds. US officials said the entities provided land leases, logistical support, and financial channels enabling the establishment of major scam sites including Tai Chang, Huanya and KK Park near Myawaddy in Karen State. According to OFAC, the DKBA both protects and directly participates in the exploitation occurring inside these compounds. The Tai Chang site, controlled by Sai Kyaw Hla and located on DKBA-held territory, has allegedly housed trafficked workers forced to carry out online investment and romance scams targeting Americans. The US cited reports of electric shocks, beatings, and other abuses against victims attempting to escape. Revenues generated by scam operations are allegedly used to fund the DKBA’s wider activities, including support for Myanmar’s military, narcotics trafficking, arms smuggling, and money laundering. The designations build on earlier actions against cyber-scam infrastructure in Cambodia, Thailand and Myanmar, including the 2025 listing of the Karen National Army (KNA) as a transnational criminal organisation, OFAC’s joint UK/US designation of Cambodia’s Prince Group as a TCO, and FinCEN’s Section 311 action severing Huione Group from the US financial system. In parallel, the creation of a multiagency Scam Center Strike Force was announced, comprising personnel from DOJ, FBI, USSS, State Department, and OFAC. The unit will coordinate sanctions, seizures, and prosecutions targeting scam-centre leaders in Myanmar, Cambodia, and Laos. DOJ said it has already seized more than $401 million in cryptocurrency linked to Southeast Asian scam networks and is pursuing further forfeiture actions. Recent operations have included the seizure of websites used by Myanmar-based groups, actions targeting Starlink terminals used to run remote scam compounds, and joint investigations with Indonesian and Thai police into networks in Bali and at KK Park. US estimates indicate that Americans lost at least $10 billion to Southeast Asian online scams in 2024, a 66% increase from the previous year. #USsanctions #OFAC #Myanmar #cyberscams

On 13 November, the National Crime Agency issued an Amber Alert warning UK financial institutions and maritime-sector firms of sophisticated sanctions-evasion networks and shadow fleets supporting Russia, Iran and North Korea (summary below). ❗ Unsure about your exposure? Sanctions SOS can help. If you need guidance on responding to the Amber Alert or strengthening controls, our team is here to assist. Contact us today: enquiries@sanctionssos.com. --- The alert, jointly issued by the NCA/OFSI/FCDO, warns that state-backed actors use opaque corporate structures, financial channels and maritime practices to move sanctioned commodities and launder revenues. Firms are urged to strengthen controls and report suspicious activity. 🔹 Expanding use of state-backed evasion networks Russia generated over $120bn in energy revenue in 2024 (about 30% of state income), some supplied to North Korea. Iran’s 2025 budget is expected to rely on energy exports for about 35% of revenue. Despite restrictions, regimes still access global markets through intermediary traders, shell entities and maritime networks that mask ownership, cargo origin and beneficiaries. Over 180 vessels linked to sanctioned actors were designated in 2025. 🔹 Shadow fleets, deceptive shipping 700-1000 ageing tankers operate as shadow fleets, concealing voyages via falsified documents, renaming and reflagging, and AIS manipulation, disabling AIS near the Persian Gulf, Gulf of Oman, Baltic Sea and Barents Sea. One highlighted network allegedly moves 1 million barrels of sanctioned oil per day, generating over $15bn annually through ship-to-ship transfers, storage and offshore shells using opaque loans and digital assets. Another network tied to UK, US and EU-designated Hossein Shamkhani shows how family-based shipping groups expand into petrochemicals and finance via multi-jurisdictional companies. 🔹 Typologies, red flags The alert highlights indicators including: - Illicit/ageing vessels in low-due-diligence registries - AIS manipulation, documentation irregularities - Repeated ship-to-ship transfers to obscure origin - Rapid incorporation of shell/isolation companies across jurisdictions - Weak websites, non-corporate email domains or overlapping directors - Complex routing, circular payments, third-party settlement, crypto use and reliance on weak AML institutions The NCA stresses that combined indicators, rather than any single one, should trigger enhanced due diligence and possible SAR filings. 🔹 What firms should do Banks, insurers, shipping companies, commodity traders and trust and company service providers are advised to assess exposure to high-risk maritime and commodities networks and report suspected sanctions breaches to OFSI/NCA. Regulated entities are reminded of obligations under POCA and the Terrorism Act. The alert notes that evasion networks are adapting quickly and that private-sector reporting remains key to disrupting revenue flows for sanctioned regimes.