The US waiver isn’t the real story. The regulatory gaps are.

With the US now issuing a waiver allowing countries to buy Russian oil, many are arguing that this simply enables Russia to continue profiting from the war in Ukraine (https://lnkd.in/eDj3xTD3). Meanwhile, the UK has refused to follow suit with many admitting this will have minimal impact on global oil prices anyway.

The uncomfortable truth is this: sanctions have been structurally ineffective for years.
Russia has continued to prosper despite sanctions dating back to 2015, and one of the biggest issues I identified in my ICA article is the regulatory gap between sanctioning regimes (https://www.int-comp.org/insight/sanctions-circumvention-at-sea/).

Take the Afkada (IMO 9311531) for example, the vessel is sanctioned under the UK regime but not by the US under OFAC.
This creates a compliance grey zone where legitimate operators face uncertainty and bad actors exploit the inconsistency.

Or the Ksena (IMO 9232888), now operating as Ailana as of August 2025.
It has shifted to a Sierra Leone flag, with operating entities incorporated in Azerbaijan.

These changes are not administrative. Put simply, they are deliberate attempts to obscure the vessel’s identity and avoid scrutiny.
So while headlines focus on whether sanctions are being “paused”, the reality is that the system has been porous for a long time.

For those interested, here is my original analysis and the raw data behind my research:
My article:
https://www.int-comp.org/insight/sanctions-circumvention-at-sea/

Raw data:
https://www.bsah.co.uk/store/p/russia-shadow-fleet-sanctions-dataset-nov-2025

I’d welcome perspectives from those implementing US and UK sanctions day‑to‑day, especially where regulatory divergence creates operational risk.

#Sanctions #Russiansanctions #Sanctionevasion #shadowfleet #maritimerisk