Navigating sanctions. Compliance has become an essential aspect of risk management for companies with international operations. As regulatory landscapes become more complex and volatile, companies are expected to include sanctions-related issues not only into their strategy frameworks, but also into their day-to-day operations. Companies face a wide range of issues in this area, including identifying exposure to restricted regions or blacklisted entities, managing enforcement risks, and maintaining current with changing regulatory duties. This includes developing and implementing comprehensive compliance initiatives, conducting thorough risk assessments, and integrating preventive measures at all levels of the company.
In the past year, there has been a noticeable increase in the rigor of sanctions enforcement worldwide. Heightened collaboration among countries like Russia, Iran, China, and North Korea to evade sanctions has pushed governments to adopt tougher enforcement measures. As a result, authorities have imposed multi-billion-dollar fines alongside criminal charges and asset freezes. The United States remains at the forefront of these efforts, with agencies such as the Department of Justice (DoJ), the Office of Foreign Assets Control (OFAC), and the Bureau of Industry and Security (BIS) leading major enforcement actions. In the early part of 2024, OFAC closed eight enforcement cases, while BIS levied fines in eleven instances, with average penalties reaching USD 1.425 million. Notably, the DoJ has brought over 60 criminal prosecutions, many related to unauthorized shipments of sensitive technology to Russia.
It is worth noting that the European Union (EU) is stepping up its sanction’s enforcement efforts as well since 2024. Member states have been coordinating more closely, with European anti-fraud office (OLAF) leading cross-border investigations. Certain key actions include Poland concluding 22 Russia-related cases, Lithuania issuing a record EUR 13.6 million fine, and Germany handing down prison sentences for military export violations. The 14th sanctions package, has introduced stricter liability rules, while at the same time the European Banking Authority has updated its guidance to ensure more consistent compliance across financial institutions.
Moreover, Russia continues to be a central target of global sanctions enforcement, with the United States concluding over 30 cases in 2024 involving exports of sensitive technologies, and Germany undertaking asset seizures and issuing custodial sentences. Enforcement efforts also keep expanding to other jurisdictions: Iran faces increased attention due to its nuclear activities and China is under scrutiny for exports linked to military industries.
Given the worldwide dynamics outlined above, companies must address several critical areas to properly manage risk and meet regulatory expectations. One major factor is how thoroughly their screening systems are tested, to make sure they’re actually triggered by what they’re supposed to. It’s also essential to have clear methodology in place for what happens when a potential match to a sanctions list comes up, including how alerts are handled, when to escalate them, and how everything is documented. The level of due diligence applied should not be one-size-fits-all; it needs to reflect the specific risks tied to each counterparty or transaction, with higher-risk cases requiring closer scrutiny. To truly stay ahead of potential issues, companies must take a well-rounded approach to risk assessment—one that relies on current data and smart analysis tools. Additionally, the framework should also outline the conditions under which relationships with specific customers, sectors, or entire geographic regions should be restricted or terminated, particularly when ongoing engagement poses legal, reputational, or operational risks.
Furthermore, maritime operations face more layers of risk than ever before. Today’s maritime environment is vast, complex, and often opaque, making it hard to spot threats early or respond quickly. From piracy and armed groups to fragile port infrastructure and rising geopolitical tensions, the environment is anything but predictable. Public intelligence, while important, often isn’t fast or specific enough for commercial needs, it’s focused on national interests, not day-to-day shipping concerns. This is why private intelligence has become such a valuable tool. It provides operators with the information they need in real time, whether it’s a developing threat along a shipping lane, unrest near a port, or signals of rising regional tensions. With that kind of intelligence, companies may shift direction, postpone departure, or boost security before things get worse. t also helps back up those decisions legally and reputation wise, showing they weren’t made on instinct but on solid ground. Insurers and flag states are increasingly encouraging this strategy with faster approvals and lower prices. And as threats expand to encompass cyber dangers, fake information campaigns, and involvement from state actors, having a solid, multi-layered intelligence setup becomes more than just useful.
Building and maintaining a strong sanctions compliance program is not just about having good internal controls, it also means having access to up-to-date, reliable intelligence from external sources. While risk assessments, system checks, and clear processes are necessary, private intelligence is becoming an important aspect of making these efforts more effective. Understanding the true risks surrounding sanctioned individuals, companies, or locations frequently requires more than simply ordinary data. Private intelligence may provide timely insights into shifting geopolitical events, reveal hidden ownership linkages, and identify high-risk individuals, information critical for full risk assessments, rigorous due diligence, and understanding when to raise concerns. It also helps to improve screening systems by reducing false positives and providing more specific alerts based on the circumstance. When authorities express concerns or issues develop, having this type of intelligence enables organizations to respond promptly and confidently, with solid proof to back up their actions.
Private intelligence is predicated on a strong compliance culture based on risk awareness. This white paper series will look at the rapidly changing world of maritime sanctions and the critical role private intelligence currently plays in risk management. With global operations under ongoing regulatory pressure, developing a compliance culture based on real-time risk awareness and incorporated into daily choices is not only crucial, but critical to remain ahead.
Disclaimer: This report is prepared by Global Risk Intelligence for general information purposes only. The information contained herein is based on data believed to be accurate and reliable at the time of publication; however, no warranty, express or implied, is given as to its accuracy, completeness, or reliability. Any opinions or forecasts represent the views of Global Risk Intelligence at the time of publication. This report does not constitute investment, legal, tax, or other professional advice; recipients should seek independent advice before making any commercial decisions.
