The Rising Tide of Secondary Sanctions: What Russian Oil Means for Global Compliance

As global tensions continue to reshape the compliance landscape, a new front has emerged: secondary sanctions on Russian oil buyers. With the U.S. escalating pressure on countries like India and China to curb Russian crude imports, organizations across industries now face a growing web of geopolitical and regulatory risk.

At the center of this issue lies a major shift in enforcement strategy, one that could have wide-reaching consequences for global trade, financial institutions, and compliance teams alike.

What’s Happening?

In July 2025, the U.S. administration announced a dramatic acceleration of secondary sanctions targeting entities that continue to purchase Russian oil, threatening action within 10–12 days of non-compliance. This marks a major policy turn, aimed at curbing the economic lifelines sustaining Russia’s war in Ukraine.

With India reportedly sourcing over 35% of its oil imports from Russia, and China maintaining strategic energy ties, the move has injected volatility into global markets and a new layer of complexity for sanctions compliance.

Why It Matters for Compliance Teams

• Regulatory Divergence: The U.S., EU, and UK sanctions regimes are not always aligned. This divergence means global businesses must manage conflicting legal obligations across jurisdictions.

• Indirect Exposure: Even if you’re not directly trading with Russia, exposure through supply chains, trade finance, or shipping partners could create secondary risk.

• Enforcement Uncertainty: With more aggressive enforcement timelines, companies must be agile and proactive and not reactive.

Compliance Best Practices in Response

To stay ahead, organizations should consider the following:

1. Reassess Third-Party Risk: Expand due diligence to include exposure to high-risk jurisdictions and indirect relationships.

2. Review Screening Controls: Ensure systems are calibrated to detect transactions and entities that could indicate indirect Russian oil dealings.

3. Update Policies and Escalation Procedures: Clearly define how secondary sanctions risk is identified, escalated, and resolved.

4. Educate Your Teams: Provide targeted training to relevant business units on the nuances of secondary sanctions and shadow trade routes.

The Bottom Line

The rise of secondary sanctions signals a new era in global sanctions enforcement, one that reaches beyond designated entities and into broader commercial ecosystems. For compliance professionals, this is both a challenge and an opportunity: a chance to reinforce controls, sharpen awareness, and drive a culture of proactive risk management.

If you are interested in tailored guidance for your business? Contact ComplySphere for a free risk assessment or subscribe to our Sanctions Weekly Insights for the latest developments.

Stay informed. Stay compliant. Stay ahead.