Sanctions Evasion Reference

Russia sanctions

Measures imposed from 2014 and greatly expanded from 2022, combining designations, sectoral restrictions, export controls and a price cap on seaborne oil.

target

Russian Federation

since

2014

authorities

7 listed below

reviewed

2026-08-20

The Russia programme is the largest coordinated sanctions effort ever attempted against a major economy, and it is the reason several techniques on this site exist in their current form.

What makes it structurally unusual

Three features distinguish it from the older comprehensive programmes.

It is coalitional. The measures are imposed in parallel by the United States, the EU, the United Kingdom, Canada, Australia, Japan, Switzerland and others, with substantial but incomplete alignment. The gaps between the regimes are narrower than in any previous programme and they are still the seams that matter.

It is not comprehensive. Russia is not embargoed. Enormous volumes of lawful trade continue, including energy trade under conditions. That means the detection problem is not “is there a transaction” but “is this particular transaction within the restriction”, which is a far harder question.

It introduced the price cap, an instrument that does not prohibit a trade but conditions the services it requires, and delegates verification to those service providers through attestations.

What it produced

The programme is responsible for the current prominence of third-country transshipment analysis, for the publication of high-priority commodity code lists, for the price cap attestation regime and the compliance apparatus around it, and for the sustained public attention to the tanker fleet operating outside mainstream insurance and flag arrangements.

Authorities administering this programme

Legal basis and official pages: OFAC Russia-related sanctions, EU restrictive measures.

Techniques that appear here

Sources

  1. Sanctions Programs and Country Information. U.S. Department of the Treasury, Office of Foreign Assets Control, 2026.
  2. Sanctions (restrictive measures). European Commission, Directorate-General for Financial Stability, 2026.
  3. Financial sanctions: consolidated list of targets. HM Treasury, Office of Financial Sanctions Implementation, 2026.
  4. Sanctions Advisory for the Maritime Oil Industry and Related Sectors. U.S. Department of the Treasury, Office of Foreign Assets Control, 2023. Price cap advisory, 12 October 2023.
  5. Entity List, Supplement No. 4 to Part 744 of the Export Administration Regulations. U.S. Bureau of Industry and Security, 2026.