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Executive Summary This week demonstrated that sanctions policy is entering a new phase. While the United States has begun implementing temporary sanctions relief for certain Iran-related activities as negotiations continue, Western governments have simultaneously increased pressure on Russia through new designations, expanded enforcement measures and continued action against sanctions circumvention networks. For compliance professionals, this creates an increasingly challenging environment. The headline may be sanctions relief. The operational reality is greater compliance complexity. Understanding where restrictions are being eased is becoming just as important as understanding where enforcement continues to intensify. Featured Analysis Sanctions Relief Does Not Mean Compliance Relief Much attention this week focused on the United States issuing temporary authorisations linked to ongoing negotiations with Iran. Some businesses may interpret this as signalling a broader return to commercial activity. That would be a mistake. Temporary licences and sanctions waivers are not the same as wholesale sanctions removal. Even where certain transactions become authorised: • Many SDN designations remain unchanged.• Counter-terrorism measures continue to apply.• Human rights sanctions remain in force.• Proliferation-related restrictions remain largely unaffected.• Secondary sanctions risks continue to exist.• Many international banks will continue adopting a cautious approach. Perhaps more importantly, the United States, European Union and United Kingdom are unlikely to move at exactly the same pace. Compliance teams should therefore avoid treating sanctions relief as a global event. Instead, firms should assess each transaction against the specific sanctions regimes that apply to their business. The greatest compliance risk over the coming months may not be breaching sanctions intentionally. It may be incorrectly assuming restrictions have disappeared. Russia: Enforcement Continues to Accelerate While attention shifted towards Iran, Russia enforcement continued to move in the opposite direction. During the past week regulators continued advancing measures aimed at: • Shadow fleet operators• Military procurement networks• Third-country financial institutions• Cryptocurrency platforms• Oil traders facilitating sanctions evasion• Banks supporting Russian financial activity• Companies involved in procurement through intermediary jurisdictions The proposed EU 21st sanctions package remains one of the most significant packages considered since 2022, demonstrating that Russia remains firmly at the centre of Western sanctions policy. At the same time, the European Union confirmed the renewal of key Russia sanctions for a further 12 months, reinforcing expectations that restrictions will remain a long-term feature of the international sanctions landscape. Emerging Theme: Facilitation Risk Has Become the Enforcement Priority Across both Russia and Iran developments, one trend continues to emerge. Regulators are increasingly focused on the organisations that enable sanctions evasion rather than only those directly subject to sanctions. Increasing attention is being given to: • Financial intermediaries• Payment processors• Trading companies• Logistics providers• Maritime service providers• Cryptocurrency exchanges• Corporate service providers For many organisations, indirect exposure now represents a greater regulatory risk than direct exposure. What Compliance Teams Should Be Reviewing Iran Review internal guidance to ensure staff understand the difference between: • General licences• Temporary sanctions relief• Full sanctions removal Authorised activity in one jurisdiction does not automatically mean activity is permitted elsewhere. Russia Continue reviewing exposure to: • Third-country counterparties• Shadow fleet indicators• High-risk trade corridors• Cryptocurrency transactions• Financial intermediaries• Maritime services Governance Ensure decision-making is properly documented. Regulators increasingly expect firms to demonstrate not only the outcome reached, but also the rationale behind that decision using the information available at the time. Key Takeaway The sanctions environment is no longer moving in one direction. Some restrictions are beginning to soften. Others are becoming significantly tougher. That means compliance programmes must become increasingly dynamic. The question organisations should now be asking is not simply: “Is this transaction sanctioned?” It is: “Which sanctions regimes apply, what relief (if any) exists, and can we demonstrate why our decision was appropriate?” That is rapidly becoming the defining compliance challenge of 2026. Comply Sphere Advisory Sanctions Intelligence | Advisory | Risk Assessment Join our Telegram channel for daily sanctions updates, breaking developments and compliance insights: https://t.me/complysphere

Executive Summary This week highlighted a significant shift in the sanctions landscape. While pressure on Russia continues to intensify through new sanctions packages, shadow fleet designations and anti-circumvention measures, growing momentum around a potential US-Iran agreement has introduced an entirely different challenge for compliance professionals. The key issue is no longer simply sanctions expansion. It is sanctions divergence. As governments pursue different geopolitical objectives, compliance teams may increasingly face situations where activity becomes permissible under one sanctions regime while remaining restricted under another. For organisations operating internationally, understanding these differences will become just as important as identifying sanctions exposure itself. Featured Analysis Iran Sanctions Relief May Be Approaching Faster Than Many Expected But Compliance Complexity Is Not Disappearing Following continued diplomatic engagement between the United States and Iran, several European governments have publicly indicated their willingness to support the gradual lifting of certain Iran-related sanctions should implementation conditions be met. For many businesses, sanctions relief creates immediate commercial interest. However, compliance teams should remain cautious. Historically, sanctions relief rarely results in a simple return to business as usual. Even if restrictions are eased: The result is likely to be increasing divergence between the United States, United Kingdom and European Union sanctions frameworks. A transaction that is permissible under one regime may remain restricted under another. In practice, this means: The biggest compliance risk may not be sanctions themselves. It may be misunderstanding which sanctions still apply. Russia: Pressure Continues to Increase EU Advances Additional Russia Measures Discussions continued this week regarding the European Union’s proposed 21st sanctions package. Current proposals include: The direction of travel remains clear: Regulators are increasingly focused on those facilitating sanctions evasion rather than solely targeting Russian entities directly. Long-Term Commitment to Russia Sanctions The European Union also moved to renew key Russia sanctions measures for an extended period, reinforcing expectations that sanctions will remain a long-term feature of the geopolitical landscape. Businesses should avoid assumptions that significant Russia sanctions relief is imminent Emerging Theme: Third-Country Risk One of the most important developments across sanctions enforcement is the continued focus on third-country facilitators. Jurisdictions frequently appearing in enforcement discussions include: Importantly, operating in these jurisdictions is not evidence of sanctions circumvention. However, regulators increasingly expect firms to understand: The focus is increasingly shifting from ownership to control. What Compliance Teams Should Be Reviewing Customer Due Diligence Review whether existing due diligence adequately identifies: Transaction Monitoring Consider whether current controls effectively identify: Iran Preparedness Prepare for potential divergence between: Relief in one jurisdiction does not automatically mean relief elsewhere. Key Takeaway The most important sanctions question in 2026 is increasingly no longer: “Is this person sanctioned?” Instead, compliance teams are being asked: “Who controls the activity, who facilitates it, and what is the true economic purpose behind the transaction?” That shift is likely to define sanctions enforcement for the remainder of the year. ComplySphere AdvisorySanctions Intelligence | Advisory | Risk Assessment 📢 Daily sanctions updates:https://t.me/complysphere

Executive Summary This week was dominated by the convergence of two major sanctions risk themes: For compliance teams across the GCC and CIS regions, the key message is that regulators are increasingly focused on facilitation risk rather than direct exposure risk. Authorities are no longer concentrating solely on sanctioned parties themselves but on the banks, intermediaries, logistics providers, traders and technology platforms enabling access to the international financial system. 1. Russia: EU Moves Towards 21st Sanctions Package The European Union proposed its 21st Russia sanctions package, representing one of the most significant financial sector measures seen since 2022. The package includes: Why It Matters The package demonstrates a clear evolution in sanctions strategy. Rather than simply adding Russian entities to sanctions lists, regulators are increasingly targeting: This creates heightened risk for GCC-based financial institutions processing transactions involving: Compliance Takeaway Institutions should review: 2. Iran: Escalation Continues Despite Diplomatic Efforts The Middle East security environment remains highly unstable. This week saw: Meanwhile, the European Union imposed new sanctions against individuals and entities linked to actions affecting maritime traffic through the Strait of Hormuz. Why It Matters Many organisations continue to assume that negotiations with Iran imply sanctions relief. Current developments suggest the opposite: Compliance Takeaway Financial institutions should maintain enhanced monitoring of: 3. OFAC Activity Signals Continued Enforcement Focus Recent US sanctions actions included: Why It Matters The United States continues to demonstrate a pattern seen throughout 2026: Negotiation does not equal enforcement relaxation. Even while diplomatic channels remain open, sanctions designations and enforcement actions continue. This remains particularly relevant for organisations assuming that geopolitical engagement automatically reduces sanctions exposure. 4. United Kingdom: Ongoing Russia Enforcement Activity The UK introduced additional Russia-related designations and maintained its focus on financial and commercial facilitators supporting Russian interests. Recent actions continue to target individuals and networks linked to sanctions circumvention and alternative payment mechanisms. Why It Matters The UK is increasingly aligning enforcement efforts with the US and EU while maintaining flexibility to pursue its own autonomous designations. For firms operating across multiple jurisdictions, divergence between UK, EU and US measures remains a key compliance challenge. Key Risk Themes for Compliance Teams 1. Third-Country Facilitation The most significant enforcement trend of 2026 remains the targeting of: Authorities increasingly view these entities as critical enablers of sanctions circumvention. 2. Maritime Risk Iran-related disruptions and continued shadow fleet activity are increasing maritime sanctions exposure. Particular attention should be paid to: 3. Financial Sector Scrutiny Banks should expect continued focus on: Outlook Looking ahead, compliance teams should monitor: Comply Sphere Advisory Assessment The sanctions environment is becoming less about identifying obvious designated parties and more about identifying indirect facilitation risk. The institutions that will manage sanctions risk most effectively over the next 12 months are those that can demonstrate: In an environment where enforcement agencies increasingly focus on the ecosystem surrounding sanctioned actors, understanding why a transaction was approved may become just as important as the approval decision itself. Follow Comply Sphere Advisory for daily sanctions intelligence:https://t.me/complysphere

Executive Summary This week’s sanctions environment has been shaped by three key themes: the expected EU 21st Russia sanctions package, continued US pressure on Iran-linked oil and maritime networks, and the emergence of Cuba as a more visible sanctions disruption risk. For compliance teams, the most important development is the continued movement away from sanctions compliance as a purely list-screening exercise. Regulators are increasingly focused on facilitation networks, third-country intermediaries, maritime structures, payment channels, and commercial ecosystems that may support sanctioned activity indirectly. Russia remains the dominant enforcement theme, with the EU expected to present its 21st sanctions package on 8–9 June. The package is expected to focus on Russia’s shadow fleet, military-industrial supply chains, and circumvention networks. Iran also remains a high-risk sanctions environment. Recent US actions and advisories continue to target oil exports, shipping activity, and financial facilitation linked to Iranian military and energy interests. A further development is Cuba’s suspension of Visa and Mastercard transactions from 6 June, citing the impact of US sanctions. This highlights how sanctions can create operational disruption beyond traditional asset freezes. For GCC institutions, particularly those operating in the UAE, the key challenge remains managing the gap between local commercial permissibility and the risk appetite of Western correspondent banks. Key Developments 1. EU 21st Russia Sanctions Package Expected The European Commission is expected to present the EU’s 21st sanctions package against Russia on 8–9 June 2026. The package is expected to focus on: Operational Impact This development reinforces several important trends: Compliance Consideration Financial institutions should reassess: The key question is no longer simply whether a party is sanctioned. The question is whether the transaction, structure, or commercial relationship could support Russia’s restricted economic or military capability. 2. Continued US Focus on Iran Oil, Shipping and Facilitation Risk Iran remains a major sanctions enforcement priority. Recent US sanctions activity and guidance continue to focus on Iranian oil exports, maritime facilitation, financial intermediaries, and entities linked to Iranian military or state interests. Operational Impact Key risk areas include: Maritime Risk Indicators Compliance teams should remain alert to: GCC Relevance For GCC-based firms, Iran risk remains particularly sensitive. Even where activity may appear locally permissible, transactions involving Iranian nexus, energy flows, shipping activity, or third-country intermediaries may trigger correspondent banking concerns. The practical risk is often not only legal prohibition. It is whether the transaction can be defended to a correspondent bank, regulator, or internal risk committee. 3. Cuba Becomes a More Visible Sanctions Disruption Risk Cuba announced that Visa and Mastercard transactions would be suspended from 6 June 2026, citing the impact of US sanctions and restrictions affecting payment processing partners. This is an important reminder that sanctions risk is not limited to direct asset freezes or designated parties. Sanctions can also disrupt: Operational Impact For financial institutions and corporates, this creates several risk considerations: Compliance Consideration Cuba should not be treated as a low-priority sanctions programme simply because it receives less attention than Russia or Iran. The latest developments show that Cuba-related sanctions can have real operational consequences, particularly where payments rely on international financial infrastructure. 4. Third-Country Facilitation Remains a Core Enforcement Theme Across Russia, Iran, and Cuba, the common theme is the increasing importance of third-country facilitation. Regulators are focusing not only on sanctioned jurisdictions themselves, but also on the networks that enable continued access to goods, finance, shipping, technology, and payment systems. High-Risk Exposure Areas Current risk indicators include: Compliance Consideration Institutions should strengthen controls around: List screening alone is not enough where the true risk sits behind the transaction structure. 5. Sanctions Risk Is Becoming More Fragmented and Exception-Driven A growing challenge for compliance teams is that sanctions frameworks are becoming more complex, fragmented, and exception-driven. This is particularly visible in areas involving: Why This Matters The practical compliance question is often no longer: “Is this prohibited?” It is increasingly: “Is this permitted, restricted, licensable, reportable, or outside our risk appetite?” That distinction matters. A transaction may be technically lawful but still unacceptable from a correspondent banking, reputational, or regulatory expectations perspective. Sector Risk Watch Banking Risk Level: High Key concerns: Trade Finance Risk Level: High Focus areas: Maritime & Commodities Risk Level: Very High Watch for: Fintech & Payments Risk Level: Elevated Particular focus on: Corporates Risk Level: Elevated Key concerns: Comply Sphere Advisory Assessment The sanctions environment continues to move towards intelligence-led enforcement. The key risk for institutions is no longer simply identifying whether a customer, vessel, entity, or payment counterparty appears on a sanctions list. The higher-risk question is whether the transaction forms part of a wider facilitation network. Regulators increasingly expect firms to understand: For GCC-based institutions, this creates a particularly complex operating environment. Local law may permit certain commercial activity, but correspondent banks and Western regulators may view the same activity through a much stricter risk lens. The firms best positioned for the next 12 months will be those that move beyond screening and build genuinely intelligence-led sanctions controls. That means stronger ownership analysis, better trade and maritime risk assessment, clearer escalation governance, and better documentation of why decisions were made. In sanctions compliance, the ability to defend the decision is becoming just as important as the decision itself. Follow Comply Sphere Advisory for daily sanctions intelligence:https://t.me/complysphere

Executive Summary This week has been dominated by two overlapping sanctions risk themes: the continued expansion of Russia sanctions enforcement targeting evasion networks and the deterioration of the Iran security environment despite ongoing diplomatic discussions. For compliance teams, the most important development is the increasing focus on third-country facilitation, particularly involving crypto networks, shipping structures, financial intermediaries, and trading companies operating outside traditional Western jurisdictions. The UK, US, and EU continue to shift attention away from direct Russian exposure and towards the ecosystems enabling sanctions circumvention. Simultaneously, renewed US action targeting Iran’s military-linked oil exports demonstrates that any sanctions relief discussions remain highly conditional and fragmented. Financial institutions should not interpret geopolitical engagement with Iran as a reduction in enforcement risk. For GCC institutions, particularly those operating in the UAE, the practical challenge remains managing divergence between local permissibility and Western enforcement expectations. Correspondent banking sensitivity continues to exceed the strict legal requirements of sanctions regulations themselves. Key Developments 1. UK Targets Russia-Linked Crypto and Financial Evasion Networks The UK announced a significant sanctions package targeting Russian-linked cryptocurrency platforms, financial facilitators, and networks allegedly supporting sanctions evasion activities. The measures included action against entities operating across Russia, the UAE, Georgia, and Kyrgyzstan.   Operational Impact This development reinforces a growing trend: Compliance Consideration Financial institutions should reassess: 2. US Expands Iran Oil and Shipping Sanctions The US imposed fresh sanctions targeting vessels, shipping companies, traders, and intermediaries allegedly involved in facilitating Iranian military-linked oil exports. Several entities across Hong Kong, Dubai, and broader maritime networks were included.   Operational Impact Key risks include: Maritime Risk Indicators Compliance teams should remain alert to: GCC Relevance Many regional trading firms continue to operate in sectors exposed to Iranian commodities, energy logistics, and shipping services. Even where activity may be locally permissible, Western banking channels remain highly sensitive to perceived sanctions exposure. 3. Growing Focus on Secondary Sanctions and Third-Country Exposure Recent regulatory messaging continues to demonstrate a clear enforcement priority: The risk is increasingly shifting from direct dealings with sanctioned parties towards indirect facilitation and network participation.   Emerging High-Risk Jurisdictions Current enforcement focus continues to include: Compliance Consideration Institutions should assess: Transaction monitoring scenarios should increasingly incorporate geographic risk indicators rather than relying solely on sanctions list screening. 4. Russia Sanctions Continue to Expand Beyond Traditional Targets The UK and wider Western allies continue broadening Russia sanctions beyond major banks and state entities towards: Operational Impact The practical effect is a growing sanctions perimeter. Financial institutions should expect: The concept of “Russian nexus” continues expanding beyond nationality or incorporation and increasingly includes commercial dependency, supply chain involvement, and facilitation activity. 5. Divergence Emerging Between Political Objectives and Enforcement Reality An important theme this week has been growing divergence between geopolitical objectives and operational sanctions implementation. The UK temporarily eased restrictions relating to certain fuels refined from Russian crude due to energy security concerns, despite maintaining broader sanctions pressure on Russia.   Why This Matters This highlights an increasingly important compliance challenge: Sanctions frameworks are becoming more fragmented and exception-driven. For compliance teams this means: The practical risk often comes not from legality itself, but from correspondent bank risk appetite. Sector Risk Watch Banking Risk Level: High Key concerns: Trade Finance Risk Level: High Focus areas: Maritime & Commodities Risk Level: Very High Watch for: Fintech & Payments Risk Level: Elevated Particular focus on: Comply Sphere Advisory Assessment The overall sanctions environment continues moving towards enforcement against networks rather than individual actors. The key risk for institutions is no longer simply identifying a sanctioned counterparty. Instead, regulators increasingly expect firms to understand: For GCC-based firms, particularly in the UAE, the challenge remains navigating the widening gap between locally permissible commercial activity and the increasingly aggressive extraterritorial posture adopted by the US, UK, and EU. The firms that will manage sanctions risk most effectively over the next 12 months are those moving beyond list screening towards genuinely intelligence-led sanctions risk assessments. Follow Comply Sphere Advisory for daily sanctions intelligence:https://t.me/complysphere

Over the past week, the global sanctions environment has continued to evolve in ways that highlight an increasingly complex reality for businesses operating internationally. What we are now seeing is not simply “more sanctions,” but growing divergence between political objectives, economic pressures, and operational enforcement. For companies involved in cross-border trade, financial services, commodities, shipping, or crypto-related activity, this creates a far more challenging risk environment than many organisations anticipated even 12 months ago. Below are the key developments and what they mean from a practical compliance perspective. Russia Energy Measures Continue to Shift Under Market Pressure One of the more notable developments this week has been the growing flexibility around restrictions connected to Russian-origin energy products. The UK has reportedly delayed elements of its restrictions relating to refined products derived from Russian crude oil, particularly diesel and jet fuel refined through third countries. At the same time, the U.S. has continued limited waivers connected to certain Russian oil movements into energy-sensitive markets. While these measures are being introduced for economic and energy-security reasons, they also create additional complexity for compliance teams and financial institutions attempting to determine what is genuinely permissible versus what remains commercially or reputationally high risk. For many firms, the challenge is no longer simply identifying direct Russian exposure. The greater concern now lies in:   indirect exposure through intermediary jurisdictions refined product origin tracing correspondent banking sensitivities shipping and logistics involvement evolving interpretations across different jurisdictions This is particularly relevant for firms operating across the GCC, where legitimate regional trade activity may still attract enhanced scrutiny from international banks or counterparties. The EU Expands Focus Beyond Traditional Sanctions Targets The EU’s latest sanctions measures continue to demonstrate a broader strategic shift away from targeting only named entities and toward disrupting the wider networks that enable sanctions circumvention. Recent measures have reportedly expanded focus on:   crypto-related services maritime logistics shadow fleet operations dual-use procurement networks third-country intermediaries This reflects a wider enforcement trend that many compliance teams are now encountering in practice: regulators are increasingly focused on the “ecosystem” surrounding high-risk activity rather than just the sanctioned party itself. For businesses, this means risk assessments can no longer rely solely on screening outcomes. Firms are increasingly expected to understand:   ownership structures transactional purpose routing behaviour geographic exposure counterparty relationships operational context The gap between basic screening and genuine sanctions intelligence continues to widen. OFAC Continues Pressure on Iran-Linked Networks OFAC activity this month has remained heavily focused on Iranian oil networks, maritime facilitation, and procurement structures linked to Asia-based trade flows. What is particularly notable is the increasing emphasis on facilitators rather than only direct Iranian counterparties. Enforcement attention now regularly extends to:   logistics providers shipping structures payment intermediaries vessel operators procurement agents layered corporate arrangements This development is especially important for firms operating in regional trade hubs such as the UAE, where transactions may appear commercially legitimate under local frameworks but still attract elevated secondary sanctions attention internationally. In practice, many firms are now discovering that the primary challenge is not necessarily whether a transaction is locally prohibited, but whether banks, insurers, or international counterparties are willing to support it. Maritime Risk Remains a Major Enforcement Focus The maritime sector continues to face heightened scrutiny, particularly around shadow fleet activity, vessel ownership opacity, AIS manipulation, and ship-to-ship transfers. Recent developments suggest regulators are also beginning to distinguish between prohibited facilitation activity and controlled end-of-life vessel disposal or recycling arrangements. While nuanced, this distinction demonstrates how sophisticated maritime sanctions enforcement has become. For compliance teams, vessel screening alone is no longer sufficient. Effective controls increasingly require:   ownership analysis historical vessel behaviour reviews routing assessments insurance validation beneficial ownership transparency trade documentation analysis Maritime compliance is rapidly becoming one of the most operationally intensive areas within sanctions risk management. Regulators Continue Reinforcing Accountability Expectations Another important reminder this week comes from recent enforcement activity linked to sanctions screening and ownership-control analysis failures. Regulators continue to make clear that reliance on third-party screening providers does not remove accountability from firms themselves. This remains highly relevant for:   banks fintechs payment institutions crypto firms trade finance businesses particularly where there are weaknesses in:   alert governance tuning methodologies ownership analysis escalation procedures list management documentation standards Increasingly, regulators expect firms to demonstrate not only that screening occurs, but that it is properly governed, tested, understood, and defensible. Comply Sphere Advisory Assessment The sanctions environment is becoming more fragmented, more operationally demanding, and more strategically complex. For many organisations, the core question is no longer: “Is this technically permissible?” but rather: “What level of financial, regulatory, reputational, or banking risk does this create?” That distinction is becoming critical. Businesses operating internationally,  particularly across the GCC, CIS, maritime, commodities, and financial services sectors,  should continue reassessing how they approach indirect exposure, intermediary risk, and evolving global enforcement expectations. The organisations that adapt early will be significantly better positioned as the sanctions landscape continues to evolve. Follow Comply Sphere Advisory for daily sanctions intelligence:https://t.me/complysphere

Executive Summary This week’s sanctions developments continued to reinforce a trend that many compliance teams are already experiencing operationally — the focus is shifting beyond direct sanctions exposure and increasingly toward facilitation risk, indirect exposure, and transaction behaviour. The US continued targeting Iranian oil shipment networks linked to China, with a noticeable focus on intermediaries, logistics facilitators, and front companies operating through jurisdictions such as the UAE, Hong Kong, and Oman. At the same time, the EU and UK continue expanding pressure on Russia’s shadow fleet ecosystem and maritime circumvention activity. For financial institutions and corporates, particularly in the GCC, the practical challenge is becoming less about identifying a sanctioned name and more about understanding: A recurring theme this week has been growing divergence between what may technically be permissible locally versus what is commercially acceptable to international correspondent banks, particularly in USD transactions. The result is increasing pressure on compliance teams to make risk-based decisions that go beyond simple screening outcomes. Key Developments OFAC Continues Pressure on Iranian Oil Networks The US announced additional sanctions targeting networks facilitating Iranian oil shipments to China. The measures focused heavily on shipping facilitators, intermediaries, and trading structures supporting the movement of Iranian crude. (Reuters)   Why This Matters Operationally This remains highly relevant for UAE-based institutions due to the continued use of: In many cases, the direct sanctioned nexus is not immediately visible. The exposure often sits within:   Key Risk Indicators Seen Across the Market   Practical Compliance Consideration Compliance teams should be particularly cautious where: The continued US focus on facilitators is another reminder that secondary sanctions exposure remains a real concern even where there is no direct dealing with a sanctioned Iranian entity.   Russia Shadow Fleet Risk Continues to Expand The EU continues preparing further Russia-related sanctions measures, with continued focus on shadow fleet activity, maritime circumvention, and support networks assisting Russian oil movements. The UK also introduced additional Russia-related sanctions targeting supply chains and facilitators. (Lloyd’s List)   Operational Impact The maritime sector continues to represent one of the highest-risk sanctions exposure areas globally. What is increasingly clear is that regulators and correspondent banks are no longer looking only at sanctioned vessel names. The focus is now much broader and includes:   Trade Finance Concerns Trade finance teams should continue paying close attention to: There is also increasing scrutiny around older tanker fleets operating with:   Correspondent Banking Sensitivity Several institutions globally continue experiencing increased RFIs from correspondent banks relating to: Importantly, many of these cases do not involve direct sanctions hits. The concern is increasingly around potential circumvention or indirect exposure.   Growing Sanctions Divergence Remains a Major Challenge Another important theme this week has been the continued divergence between US sanctions expectations and the approach taken by other jurisdictions, particularly in relation to China and Russia-linked trade activity. This divergence is becoming increasingly difficult operationally for multinational firms and financial institutions operating across:   What This Means in Practice A transaction may: This is particularly relevant in: The challenge for compliance teams is no longer purely regulatory. It is increasingly about understanding:   Maritime Risk Environment Remains Elevated Maritime risk linked to Iran and regional geopolitical tensions remains elevated, particularly around the Strait of Hormuz and broader Gulf shipping routes.   Key Concerns   Practical Risk Areas for Financial Institutions For many institutions, maritime exposure is becoming one of the most difficult areas to assess effectively due to the combination of:   GCC / UAE Focus   Increasing Pressure on UAE Financial Institutions For UAE institutions, the operational challenge continues to centre around balancing: While UAE regulations remain primarily aligned to UN and UAE sanctions obligations, international banking partners — particularly US correspondents — are often applying significantly broader risk expectations.   What We Are Seeing Increasingly Across the Market   Important Reality for Compliance Teams A transaction does not need to breach UAE law to create significant operational problems. Correspondent banks may still: That gap between legal permissibility and correspondent risk appetite is becoming one of the defining challenges for GCC compliance functions.   Key Themes to Watch   Russia   Iran   Maritime Sector   Correspondent Banking   Practical Actions for Compliance Teams Financial institutions and corporates should consider:   Comply Sphere Advisory Assessment This week reinforced a point that is becoming increasingly clear across the industry: Sanctions risk today is less about obvious direct exposure and increasingly about understanding hidden connections, facilitation networks, and broader transaction behaviour. For compliance teams, particularly in the GCC, the challenge is no longer simply identifying whether a name appears on a sanctions list. The real challenge is determining whether the transaction itself makes sense, whether the structure creates indirect exposure, and whether a correspondent bank would be comfortable processing it. Follow Comply Sphere Advisory for daily sanctions intelligence:https://t.me/complysphere