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The Angola Offshore & Financial Crime Index: 2024-2026 Update

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The Angola Offshore & Financial Crime Index: 2024-2026 Update

Date: March 18, 2026
Source Compilation: Ministรฉrio das Finanรงas de Angola, Administraรงรฃo Geral Tributรกria (AGT), FATF, ICIJ, PwC, Al Jazeera, Finance Uncovered

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Part I: Executive Summary | Part II: Tax Framework & CFC Rules | Part III: FATF Grey List Status | Part IV: Luanda Leaks โ€“ Offshore Entities Exposed | Part V: Key Individuals & Beneficiaries | Part VI: Offshore Jurisdictions of Concern | Part VII: Domestic Tax Incentives | Summary Statistics

Part I: Executive Summary {#executive-summary}

This report provides a comprehensive overview of the regulatory, tax, and offshore landscape in Angola. As of 2024-2026, Angola remains under significant international scrutiny due to its “grey list” status with the Financial Action Task Force (FATF) and the ongoing fallout from major corruption investigations such as the “Luanda Leaks.”

Key Findings:

ยท Corporate Income Tax (CIT): The general CIT rate in Angola has been reduced from 30% to 25%. However, oil companies are subject to a higher rate of 35%, and mining companies are taxed at 30% .
ยท FATF Grey List Status: As of February 2026, Angola remains on the FATF’s list of Jurisdictions under Increased Monitoring (the “grey list”). The country is working to implement an action plan to address deficiencies in its Anti-Money Laundering and Counter-Terrorist Financing (AML/CFT) framework .
ยท Luanda Leaks Fallout: Investigations, most notably the Luanda Leaks (2020) and subsequent follow-ups, have exposed a vast network of over 400 offshore companies used by the Angolan elite to divert billions in state funds .
ยท Controlled Foreign Company (CFC) Rules: Angola does not currently have a comprehensive CFC regime. However, it has introduced specific anti-avoidance measures and transfer pricing regulations to combat base erosion .
ยท Transparency Efforts: Angola has made efforts to improve tax transparency and has signed several Double Taxation Agreements (DTAs), although its network remains smaller than many of its peers. It is a member of the Global Forum on Transparency and Exchange of Information for Tax Purposes .

Part II: Tax Framework & Offshore-Related Rules {#part-i}

Corporate Income Tax (CIT) โ€“ 2026 Update

As of January 1, 2026, Angola implemented changes to its corporate tax structure, reducing the general rate to encourage investment .

Activity Sector CIT Rate Notes
General Activities 25% Reduced from 30% (effective Jan 2026)
Oil & Gas Sector 35% Subject to separate petroleum tax law
Mining Sector 30% Specific mining regime applies
Agriculture & Industry Variable Incentives available under Investment Law

Source: Mercans, PwC

Absence of Controlled Foreign Corporation (CFC) Rules

Angola does not currently have formal CFC rules in its tax legislation .

ยท Implication: Angolan parent companies with subsidiaries in low-tax jurisdictions (e.g., BVI, Mauritius, Malta) are not subject to current taxation on the undistributed profits of those subsidiaries.
ยท Taxation Point: Income from foreign subsidiaries is typically only taxed in Angola when repatriated as dividends.
ยท Anti-Avoidance: Angola has introduced transfer pricing regulations aligned with OECD principles to combat profit shifting through related-party transactions .

Transfer Pricing & Anti-Avoidance

ยท Transfer Pricing: Transactions between related parties must be conducted at arm’s length. Documentation requirements exist for multinational enterprises operating in Angola .
ยท General Anti-Abuse Rule (GAAR): Tax authorities can challenge transactions lacking economic substance.

Part III: FATF Grey List Status (2024-2026) {#part-ii}

Current Status โ€“ February 2026 Update

As of the February 2026 FATF plenary, Angola remains on the list of Jurisdictions under Increased Monitoring, commonly known as the “grey list” .

FATF Statement (February 2026):

“Angola has made significant progress to improve its AML/CFT framework and has been working with the FATF to implement its action plan. The country will continue to work with the FATF to address the remaining strategic deficiencies.”

Angola’s FATF Action Plan

Angola is required to address several strategic deficiencies, including:

Action Item Status (as of 2026)
Enhancing risk-based supervision of financial institutions In progress
Improving beneficial ownership transparency Legislative reforms ongoing
Increasing international cooperation and information exchange Active participation
Strengthening investigation and prosecution of money laundering Capacity building underway

FATF Lists โ€“ February 2026

Black List (High-Risk Jurisdictions Subject to Call for Action)

Jurisdiction Status
North Korea High-risk
Iran High-risk
Myanmar High-risk

Grey List (Jurisdictions Under Increased Monitoring) โ€“ February 2026

Jurisdiction Jurisdiction
Algeria Lebanon
Angola Monaco
Bulgaria Mozambique
Burkina Faso Namibia
Cameroon Nigeria
Cรดte d’Ivoire South Africa
Croatia South Sudan
Democratic Republic of the Congo Syria
Haiti Tanzania
Kenya Venezuela
Laos Vietnam
Yemen

Source: FATF (February 13, 2026)

Implications of Grey List Status

For Angola, FATF grey list status carries significant consequences:

ยท Enhanced Due Diligence: Foreign financial institutions apply stricter scrutiny to transactions involving Angolan entities.
ยท Correspondent Banking: Risk of loss of correspondent banking relationships.
ยท Investment Impact: Increased compliance costs for foreign investors.
ยท International Reputation: Signals ongoing AML/CFT deficiencies to global partners.

Part IV: Luanda Leaks โ€“ Offshore Entities Exposed {#part-iii}

The Luanda Leaks (2020), coordinated by the International Consortium of Investigative Journalists (ICIJ), exposed a vast network of over 400 offshore companies used by Angola’s elite, particularly the family of former President Josรฉ Eduardo dos Santos.

Key Offshore Entities Identified

Entity Name Jurisdiction Associated Case/Person
Kwanza Invest Angola / Switzerland Investment firm linked to Josรฉ Filomeno dos Santos
Terra 9 Malta Holding company used by Isabel dos Santos for telecommunications investments
Unitel International Holdings Netherlands Used to funnel hundreds of millions in loans from Angolan telecom provider Unitel
Exem Energy BV Netherlands Holding company used to acquire stake in Portuguese energy giant Galp
Matter Business Solutions Dubai (UAE) Consulting firm that received over $115 million in suspicious payments from Sonangol
Ironsea / Athol Limited BVI Shell companies used to purchase luxury real estate in the UK and Monaco
Winterfell Investments Limited BVI Received transfers from Angolan state oil company Sonangol
Santorini Investments Limited BVI Linked to Isabel dos Santos’ network

Sources: ICIJ, Al Jazeera, Finance Uncovered

The Scale of Diversion

ยท Total Offshore Entities: 400+ shell companies identified.
ยท Funds Diverted: Billions of dollars from state enterprises, including Sonangol (state oil company), Unitel (telecom), and the Sovereign Wealth Fund (FSDEA) .
ยท Asset Locations: Luxury real estate in the UK, Monaco, Portugal, and Switzerland; stakes in European energy and telecommunications companies.

Part V: Key Individuals & Beneficiaries {#part-iv}

The following “Politically Exposed Persons” (PEPs) and their associates have been prominently identified in international leaks and legal proceedings.

Name Role/Position Offshore Links Status/Source
Isabel dos Santos Daughter of former President; businesswoman Vast network of 400+ offshore companies; assets frozen in multiple jurisdictions UK sanctions (2024); asset freezes in Portugal, Angola
Sindika Dokolo Late husband of Isabel dos Santos Held stakes in diamond (De Grisogono) and energy companies via shell structures Deceased; estate under investigation
Josรฉ Filomeno “Zenu” dos Santos Son of former President; former head of Sovereign Wealth Fund (FSDEA) Linked to Kwanza Invest; $500 million fraud scheme Sentenced to prison (2020); appeals ongoing
Manuel Vicente Former Vice President; former head of Sonangol Central figure in corruption investigations in Angola and Portugal Under investigation
Manuel Rabelais Former Media Minister Beneficiary of offshore accounts (Pandora Papers) Named in ICIJ leaks
Jean-Claude Bastos de Morais Swiss-Angolan financier; managed FSDEA Set up offshore structures to manage (and allegedly divert) sovereign wealth Under investigation

Sources: ICIJ, Al Jazeera, Pandora Papers

The Isabel dos Santos Network

Isabel dos Santos, once Africa’s richest woman, is accused of embezzling billions from state companies through a complex web of offshore structures. In December 2024, the UK imposed sanctions on her, designating her assets as “dirty money” and freezing her holdings in the UK .

Modus Operandi:

  1. Offshore Incorporation: Establishing shell companies in BVI, Malta, Netherlands, and Mauritius.
  2. Intermediary Contracts: Using consulting firms (e.g., Matter Business Solutions in Dubai) to receive suspicious payments from state companies.
  3. Loan Diversion: Funneling loans from state-owned enterprises (e.g., Unitel) through Dutch holding companies.
  4. Asset Acquisition: Purchasing luxury real estate in the UK, Monaco, and Portugal through BVI vehicles.

Part VI: Offshore Jurisdictions of Concern (Angolan Perspective) {#part-v}

While Angola does not publish a formal “blacklist,” its regulatory authorities and financial institutions apply enhanced due diligence to transactions involving certain jurisdictions based on Luanda Leaks exposure and FATF listings.

Jurisdictions Frequently Used in Angolan Offshore Structures

Jurisdiction Role/Frequency Notable Cases
British Virgin Islands (BVI) Very High Ironsea, Athol, Winterfell, Santorini
Netherlands High Unitel International Holdings, Exem Energy BV
Malta Medium Terra 9 (Isabel dos Santos)
Mauritius Medium Financial intermediary structures
Dubai (UAE) Medium Matter Business Solutions ($115M payments)
Switzerland Medium Kwanza Invest; bank accounts
Portugal Emerging Real estate and corporate investments

FATF High-Risk Jurisdictions

Angolan financial institutions are required to apply countermeasures to transactions involving FATF blacklist jurisdictions:

ยท North Korea
ยท Iran
ยท Myanmar

EU Blacklist (February 2025)

Several jurisdictions that appear in Angolan offshore structures are on the EU list of non-cooperative jurisdictions :

Jurisdiction EU Status
Panama Non-cooperative
US Virgin Islands Non-cooperative
Vanuatu Non-cooperative
Trinidad and Tobago Non-cooperative

Source: European Council (February 2025)

Part VII: Domestic Tax Incentives and Special Regimes {#part-vi}

Angola offers several incentives to attract foreign investment, primarily through its Special Economic Zones (ZEE) and sector-specific regimes.

  1. Luanda-Bengo Special Economic Zone (ZEE)

The Zona Econรณmica Especial (ZEE) Luanda-Bengo offers significant tax benefits for qualified industrial and agricultural projects .

Incentive Type Benefit
Corporate Income Tax (CIT) Exemption for initial period; reduced rates thereafter
Property Tax (IPU) Exemption for qualifying projects
Customs Duties Exemption on imported equipment and raw materials
Industrial Tax Reduced rates

  1. Oil and Gas Sector Incentives

Despite the high 35% CIT rate, specific tax deductions are available for:

ยท Investments in marginal fields
ยท Deep-water exploration projects
ยท Research and development activities

  1. Micro and Small Business Incentives

To encourage formalization of the economy, reduced CIT rates apply to qualifying small enterprises :

Turnover Threshold CIT Rate
Up to AOA 10 million 2%
AOA 10-25 million 4%
AOA 25-50 million 6%

  1. Investment Law Incentives

Projects approved under Angola’s Private Investment Law may qualify for:

ยท Customs duty exemptions
ยท Reduced CIT rates for a defined period
ยท Accelerated depreciation allowances

Sources: Luanda-Bengo ZEE, PwC

Summary Statistics {#summary}

Category Count / Value
General CIT Rate 25% (effective Jan 2026)
Oil & Gas CIT Rate 35%
Mining CIT Rate 30%
CFC Rules None (as of 2026)
FATF Status Grey List (February 2026)
FATF Black List Countries (Global) 3 (North Korea, Iran, Myanmar)
FATF Grey List Countries (Global) 25+ (including Angola)
Luanda Leaks Offshore Entities Exposed 400+
Key Individuals Named 7+ (dos Santos family, Vicente, Rabelais, Bastos de Morais)
Primary Offshore Jurisdictions Used BVI, Netherlands, Malta, Mauritius, UAE, Switzerland
ZEE Luanda-Bengo Incentives CIT/Property/Customs exemptions

Sources

  1. Mercans. (2026). Angola โ€“ Changes in Tax Rates โ€“ 1st January 2026.
  2. PwC. (2025, December 15). Angola โ€“ Corporate โ€“ Other taxes โ€“ Worldwide Tax Summaries.
  3. FATF. (2026, February 13). Jurisdictions under Increased Monitoring โ€“ February 2026.
  4. AML UAE. (2025, October 24). FATF Grey List Update October 2025.
  5. OECD. (2025). Global Forum on Transparency and Exchange of Information: Angola Profile.
  6. Al Jazeera. (2020, August 14). Angola: Former president’s son Zenu dos Santos jailed for fraud.
  7. ICIJ. (2020). Luanda Leaks: How Africa’s richest woman exploited family ties, shell companies and inside deals.
  8. Al Jazeera. (2024, December 18). Isabel dos Santos: From Africa’s richest woman to ‘dirty money’ UK sanctions.
  9. Finance Uncovered. (2020, January 22). Luanda Leaks: Isabel dos Santos and her Cape Verde banking paradise.
  10. Foreign Policy Association. (2024). Angola’s Story Of Politically Exposed Persons And Debt Traps.
  11. ICIJ. (2021, October 4). Pandora Papers: The power players.
  12. Luanda-Bengo ZEE. (2024). Investment Incentives and Tax Benefits.
  13. European Council. (2025, February 18). Timeline โ€“ EU list of non-cooperative jurisdictions.

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Report Date: March 18, 2026
Data Sources: Ministรฉrio das Finanรงas de Angola, Administraรงรฃo Geral Tributรกria (AGT), FATF, ICIJ, PwC, Al Jazeera, Finance Uncovered, European Council.



Bernd Pulch โ€” Bio
Bernd Pulch โ€” Bio Photo

Bernd Pulch (M.A.) is a forensic expert, founder of Aristotle AI, entrepreneur, political commentator, satirist, and investigative journalist covering lawfare, media control, investment, real estate, and geopolitics. His work examines how legal systems are weaponized, how capital flows shape policy, how artificial intelligence concentrates power, and what democracy loses when courts and markets become battlefields. Active in the German and international media landscape, his analyses appear regularly on this platform.

Full bio โ†’ | Support the investigation โ†’

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The Algeria Offshore & Financial Crime Index: 2024-2025 Update

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The Algeria Offshore & Financial Crime Index: 2024-2025 Update

Date: March 16, 2026
Source Compilation: Algerian Ministry of Finance, Direction Gรฉnรฉrale des Impรดts (DGI), PwC, EY, KPMG, ICIJ, The New York Times, Middle East Eye

Jump to Section

Part I: Executive Summary | Part II: Tax Framework & Offshore Rules | Part III: High-Profile Offshore Cases | Part IV: Key Individuals & Beneficiaries | Part V: Offshore Jurisdictions of Concern | Part VI: Domestic Tax Incentive Zones | Summary Statistics

Part I: Executive Summary {#executive-summary}

This report provides a structured overview of the regulatory and tax landscape in Algeria concerning offshore entities, jurisdictions, and specific high-profile cases involving offshore structures. Algeria’s tax system is characterized by its territoriality and the absence of specific Controlled Foreign Corporation (CFC) rules, though it has increasingly focused on anti-money laundering and international tax transparency through the Finance Law for 2025 .

Key Findings:

ยท Tiered Corporate Income Tax (CIT): Algeria applies a differentiated CIT rate system: 19% for manufacturing activities, 23% for construction and public works, and 26% for other activities (including services and trade) .
ยท Absence of CFC Rules: Currently, Algeria does not have formal Controlled Foreign Corporation (CFC) rules, meaning income of foreign subsidiaries is generally not taxed at the level of the Algerian parent company until distributed as dividends .
ยท Offshore Scrutiny: High-profile corruption scandals, such as the Sonatrach-Saipem case, have highlighted the extensive use of offshore shell companies by Algerian officials and middlemen to facilitate bribes and capital flight .
ยท ICIJ Links: Multiple Algerian individuals and entities have been exposed through international investigations, including the Panama Papers and Pandora Papers .
ยท Domestic Incentives: Tax exemptions and reductions are available for activities in the Southern regions and for encouraged sectors like manufacturing and tourism .

Part II: Tax Framework & Offshore-Related Rules {#part-i}

Corporate Income Tax (CIT) โ€“ Finance Law 2025

Algeria’s tax system operates under a territorial principle, meaning generally only income sourced in Algeria is taxable. The Finance Law for 2025 introduced adjustments to the tiered CIT rates .

Activity Sector CIT Rate Legal Basis
Manufacturing Activities 19% Finance Law 2025
Construction & Public Works 23% Finance Law 2025
Other Activities (Services, Trade, etc.) 26% Finance Law 2025
Hydrocarbons Sector Special regimes apply Separate tax code

Source: PwC, EY

Absence of Controlled Foreign Corporation (CFC) Rules

Unlike many OECD and EU member states, Algeria does not currently have formal CFC rules in its tax legislation .

ยท Implication: Algerian parent companies with subsidiaries in low-tax jurisdictions (e.g., BVI, Panama, Hong Kong) are not subject to current taxation on the undistributed profits of those subsidiaries.
ยท Taxation Point: Income from foreign subsidiaries is typically only taxed in Algeria when repatriated as dividends, subject to standard CIT rates and potential foreign tax credits.
ยท Future Outlook: International pressure through the OECD/G20 Inclusive Framework on BEPS may eventually lead to CFC rule adoption, but no legislation is currently pending.

Transfer Pricing & Anti-Avoidance

While CFC rules are absent, Algeria does have general anti-abuse provisions and transfer pricing rules aligned with OECD principles .

ยท Transfer Pricing: Transactions between related parties must be conducted at arm’s length. Documentation requirements exist for multinational enterprises operating in Algeria.
ยท General Anti-Abuse Rule (GAAR): Tax authorities can challenge transactions lacking economic substance or entered into primarily for tax avoidance.

Part III: High-Profile Offshore Cases (Panama Papers & Pandora Papers) {#part-ii}

Algeria has been featured prominently in international offshore leak investigations, revealing the hidden wealth and financial networks of political elites and intermediaries.

  1. The Sonatrach-Saipem Bribery Scandal

One of the largest corruption cases involving Algerian offshore structures centered on state oil company Sonatrach and Italian energy firm Saipem .

Detail Information
Amount Involved Over $275 million in bribes
Key Middleman Farid Bedjaoui
Offshore Vehicles Network of shell companies in Panama, BVI, Hong Kong
Purpose Securing energy contracts worth billions

  1. Panama Papers Exposures

The Panama Papers (2016) and subsequent ICIJ investigations revealed multiple offshore entities linked to Algerian officials .

Offshore Entities Identified

Entity Name Jurisdiction Associated Person/Case
Royal Arrival Corp. Panama Linked to Abdeslam Bouchouareb (Former Minister)
Collingdale Consultants Inc. Panama Linked to Farid Bedjaoui and family of Chakib Khelil
CEC Group Limited BVI / Panama Acted as intermediary for multiple Algerian offshore structures
Pearl Partners Limited Hong Kong Used in Sonatrach-Saipem bribery scheme
Mincape Limited BVI Linked to energy sector middlemen

Source: ICIJ Offshore Leaks Database

  1. Pandora Papers Connections

The Pandora Papers (2021) further detailed the use of offshore trusts and companies by associates of former President Abdelaziz Bouteflika and other elites, particularly involving real estate holdings in Europe and shell companies in the British Virgin Islands.

Part IV: Key Individuals & Beneficiaries {#part-iii}

The following individuals have been prominently named in offshore leaks or government investigations as beneficiaries, officers, or intermediaries of offshore structures.

Name Role/Position Offshore Links Status/Source
Abdeslam Bouchouareb Former Minister of Industry and Mines Sole owner of Royal Arrival Corp. (Panama); assets managed via Luxembourg ICIJ
Farid Bedjaoui International middleman Funneled $275M in bribes through offshore shell companies; named in Saipem case NYT, MEE
Chakib Khelil Former Minister of Energy Associates and family linked to offshore accounts; diverted funds from oil contracts ICIJ
Najat Arafat Wife of Chakib Khelil Named in investigations concerning offshore accounts in Switzerland and Panama ICIJ
Rรฉda Hemche Former Chief of Staff at Sonatrach Linked to facilitation of offshore transactions in energy sector MEE

Sources: ICIJ, The New York Times, Middle East Eye

Modus Operandi

Investigations revealed a consistent pattern:

  1. Offshore Incorporation: Establishing shell companies in Panama, BVI, or Hong Kong.
  2. Intermediaries: Using middlemen (e.g., Farid Bedjaoui) to manage transactions and obscure beneficial ownership.
  3. Bribe Payments: Routing funds through multiple jurisdictions to conceal origin and destination.
  4. Asset Holding: Using offshore structures to acquire and hold luxury real estate, primarily in Europe and the UAE.

Part V: Offshore Jurisdictions of Concern {#part-iv}

Based on the ICIJ leaks and corruption investigations, the following jurisdictions have been most frequently used in Algerian-linked offshore structures:

Jurisdiction Role/Frequency Notable Cases
Panama Very High Royal Arrival Corp., Collingdale Consultants, CEC Group
British Virgin Islands (BVI) High Mincape Limited, CEC Group
Hong Kong Medium Pearl Partners Limited (Saipem case)
Luxembourg Medium Asset management for Bouchouareb
Switzerland Medium Bank accounts for Khelil/Arafat
United Arab Emirates (UAE) Emerging Real estate and trade hub

EU List of Non-Cooperative Jurisdictions

Algeria itself is not on any EU tax blacklist. However, several jurisdictions frequently used in Algerian offshore structures appear on the EU blacklist (February 2025 update) :

ยท Panama (Non-cooperative โ€“ exchange of information concerns)
ยท US Virgin Islands (Non-cooperative โ€“ harmful tax regimes)
ยท Vanuatu (Non-cooperative โ€“ transparency issues)

Source: European Council (February 18, 2025)

Part VI: Domestic Tax Incentive Zones {#part-v}

Algeria provides significant tax breaks within its borders to encourage regional development and specific industries. These are not “offshore” in the traditional sense but function as low-tax zones within Algeria.

Southern Regions Incentive

A 50% reduction on Global Income Tax (IRG) or Corporate Income Tax (IBS) is granted for a period of 10 years for activities carried out in several southern provinces .

Eligible Provinces
Adrar
Illizi
Tamanrasset
Tindouf
Bรฉchar
Ouargla
Laghouat
Other designated southern zones

Investment Promotion (ANDI)

Projects approved by the National Investment Development Agency (ANDI) can benefit from significant tax exemptions .

Incentive Type Duration Details
CIT Exemption 3 to 10 years Depending on project location and importance
VAT Exemption Varies On imported or locally acquired goods/services
Land Tax Exemption Varies For the duration of the project

Source: KPMG

Manufacturing Sector Incentive

The reduced 19% CIT rate for manufacturing activities serves as a structural incentive to promote local production and reduce import dependency .

Summary Statistics {#summary}

Category Count / Value
CIT Rate โ€“ Manufacturing 19%
CIT Rate โ€“ Construction 23%
CIT Rate โ€“ Other Activities 26%
CFC Rules None (as of 2025)
High-Profile Offshore Entities (ICIJ) 5+ (Royal Arrival, Collingdale, CEC, Pearl, Mincape)
Key Individuals Named 5+ (Bouchouareb, Bedjaoui, Khelil, Arafat, Hemche)
Offshore Jurisdictions Used Panama, BVI, Hong Kong, Luxembourg, Switzerland, UAE
Southern Provinces with Tax Incentives 8+
ANDI Tax Exemption Duration 3-10 years

Sources

  1. PwC. (2025, July 14). Algeria โ€“ Corporate โ€“ Taxes on corporate income.
  2. EY. (2025, January 17). Algeria enacts 2025 Finance Law with key measures applicable to corporations.
  3. ICIJ. (2019, May 2). ‘Get them all out!’ The Panama Papers connections to Algeria’s latest revolution.
  4. Middle East Eye. (2020, May 14). Algeria and Lebanon embroiled in defective fuel scandal.
  5. KPMG. (2025, January 1). Finance Law 2025 Key Measures.
  6. ICIJ Offshore Leaks Database. (n.d.). Abdelsam Bouchouareb โ€“ Profile.
  7. The New York Times. (2016, July 25). Panama Papers Reveal Wide Use of Shell Companies by African Officials.
  8. KPMG. (2025, April 1). Guide to Investing in Algeria 2025.
  9. European Council. (2025, February 18). Timeline โ€“ EU list of non-cooperative jurisdictions.

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Report Date: March 16, 2026
Data Sources: Algerian Ministry of Finance, Direction Gรฉnรฉrale des Impรดts (DGI), PwC, EY, KPMG, ICIJ, The New York Times, Middle East Eye, European Council.



Bernd Pulch โ€” Bio
Bernd Pulch โ€” Bio Photo

Bernd Pulch (M.A.) is a forensic expert, founder of Aristotle AI, entrepreneur, political commentator, satirist, and investigative journalist covering lawfare, media control, investment, real estate, and geopolitics. His work examines how legal systems are weaponized, how capital flows shape policy, how artificial intelligence concentrates power, and what democracy loses when courts and markets become battlefields. Active in the German and international media landscape, his analyses appear regularly on this platform.

Full bio โ†’ | Support the investigation โ†’

The Russia Offshore & Sanctions Index: 2024-2025 Update

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The Russia Offshore & Sanctions Index: 2024-2025 Update

Date: March 10, 2026
Source Compilation: OFAC, EU External Action Service, UK Treasury, ICIJ, Atlantic Council

Jump to Section

Part I: Executive Summary | Part II: Sanctioned Oligarchs | Part III: Evasion Networks | Part IV: Offshore Jurisdictions | Part V: Corporate Structures | Part VI: Regulatory Actions | Part VII: Key Individuals | Summary Stats

Part I: Executive Summary {#executive-summary}

This report provides a structured overview of newly sanctioned Russian individuals and entities with offshore connections, based on actions taken by the United States, European Union, and United Kingdom between 2024 and early 2026. The data integrates official sources including OFAC, the EU External Action Service, UK His Majesty’s Treasury, and the ICIJ Offshore Leaks database.

Key Trends:

ยท Expanded Sectoral Sanctions: Targeting remaining Russian financial institutions, energy exports, and technology imports.
ยท Focus on Evasion Networks: Disruption of third-country facilitators, particularly in the UAE, Tรผrkiye, and Eurasia, using shell companies and virtual assets.
ยท Navalny-Related Designations: Posthumous and ongoing sanctions against individuals linked to the imprisonment and death of Alexei Navalny.
ยท Shadow Fleet Targeting: Sanctions on tankers and shipping companies involved in transporting Russian oil above the price cap.

Part II: Sanctioned Oligarchs & Political Figures (2024-2025) {#part-i}

The following individuals represent a selection of high-profile designations and investigations during the reporting period.

  1. Andrei Guryev & Family (Phosagro)

ยท Connection: Major shareholder of Phosagro, one of the world’s largest phosphate fertilizer producers.
ยท Sanctions Action (2024): UK and EU imposed asset freezes and travel bans, targeting his luxury assets in London and Verbier, Switzerland.
ยท Offshore Links: Previously linked to BVI and Cypriot entities in the Pandora Papers, used to hold stakes in mining assets and luxury real estate.
ยท Status: Sanctioned; assets frozen.

  1. Alexei Mordashov (Severstal)

ยท Connection: Primary beneficiary of Severstal, a major Russian steel and mining company.
ยท Sanctions Action (2024): EU sanctions maintained and expanded; his luxury yacht and villa in Sardinia were previously seized but legal challenges continue regarding ownership structures.
ยท Offshore Links: Extensive use of Cypriot holding companies (e.g., Rayglow Ltd.) to own international assets, as documented in the Cyprus Confidential leaks.
ยท Status: Sanctioned; legal battles over seized assets ongoing.

  1. Navalny-Related Designations (2024)

In response to the death of Alexei Navalny, coordinated sanctions were imposed on individuals connected to his imprisonment and prosecution.

Name Role Sanctioning Body Notes
Alexander Bastrykin Head of Russia’s Investigative Committee EU, UK Oversaw investigations into Navalny
Prison Officials Multiple directors of penal colonies EU, UK Where Navalny was held
Prosecutors & Judges Involved in Navalny’s legal cases EU, UK 33 individuals total

  1. Other Key Designations (2024-2025)

ยท Military Leadership: Continued sanctions against high-ranking military staff involved in the ongoing conflict.
ยท Regional Governors: Asset freezes on officials in occupied territories of Ukraine.
ยท Family Members: Sanctions expanded to adult children and spouses of already-designated oligarchs to prevent asset transfers.

Part III: Sanctions Evasion Networks & Facilitators {#part-ii}

Enforcement in 2024-2025 has increasingly focused on third-country nationals and companies that help Russia procure banned technology or move money.

  1. Virtual Asset Service Providers (VASPs)

ยท Case: OFAC designated several Russia-linked cryptocurrency exchanges and VASPs operating out of the UAE and Eurasia.
ยท Method: Used to convert rubles into stablecoins and transfer value internationally, bypassing the SWIFT system.
ยท Key Target: Networks facilitating payments for dual-use electronics (drones, microchips) used in weapons manufacturing.

  1. Tรผrkiye & UAE Transshipment Hubs

ยท Network: Companies in Tรผrkiye and the UAE have been designated for shipping European-made machine tools and microelectronics to Russian end-users.
ยท Method: Use of shell companies in free trade zones to obscure the final destination.
ยท UK/EU Action: Asset freezes and export bans on specific trading houses in Istanbul and Dubai.

  1. The “Shadow Fleet” of Oil Tankers

ยท Target: OFAC and the UK added dozens of individual tankers to the sanctions list.
ยท Method: Aging vessels with opaque ownership (often registered in Liberia, Marshall Islands, or Panama) used to transport Russian crude above the G7 price cap.
ยท Financial Impact: Shipping costs increased; insurance becomes difficult for designated vessels.

Part IV: Offshore Jurisdictions of Concern (2024-2025) {#part-iii}

While traditional havens like Cyprus and the BVI remain in the data, new hubs have emerged as primary vehicles for sanctions evasion.

Jurisdiction Role Current Status
Cyprus Historical holding location for oligarch wealth (corporate shares, real estate). Scrutiny increased; Russian entities winding down or relocating.
British Virgin Islands Shell company formation for holding international assets. Still present in leaks; compliance pressure increasing.
United Arab Emirates Primary new hub for private wealth, real estate, and crypto asset movement. Sanctions applied to facilitators based in Dubai; strict regulatory compliance demanded by US/UK.
Kazakhstan Used for parallel imports and re-export of sanctioned goods. Monitoring increased; some companies designated.
Hong Kong Potential new banking hub for Russian entities cut off from SWIFT. Investigations ongoing into trade-based money laundering.

Part V: Offshore Corporate Structures (ICIJ Data) {#part-iv}

The ICIJ’s Cyprus Confidential (2023-2024) and Pandora Papers databases continue to provide context for current sanctions, revealing the hidden owners of assets now being frozen.

Key Entities Linked to Sanctioned Russians

Company Name Jurisdiction Linked Individual Notes
Rayglow Ltd. Cyprus Alexei Mordashov Held shares in Severstal; frozen.
Hammersmith Services BVI Andrey Guryev Investment vehicle; sanctioned.
Carina Global BVI Suleyman Kerimov Holding company for assets; previously sanctioned.
Brooksby Trading Cyprus Iskander Makhmudov Mining assets; sanctioned.

Major Russian Corporations with Offshore Dependencies

ยท Severstal: Complex ownership via Cyprus.
ยท Phosagro: Shareholder structures involving Jersey and Cyprus.
ยท Lukoil: Historically used Dutch and Cypriot holding companies.
ยท Sberbank & VTB: Sanctions have severed most correspondent banking relationships, forcing reliance on domestic and Chinese systems.

Sources: ICIJ Offshore Leaks Database, Cyprus Confidential

Part VI: Regulatory Enforcement & Trends (2024-2025) {#part-v}

Sanctions enforcement has shifted from simply listing individuals to actively dismantling the support infrastructure.

OFAC & UK Enforcement Actions

Focus Area Description Number of Actions (Est.)
Tankers (Shadow Fleet) Designation of specific vessels and shipping management companies. 50+ vessels
Third-Country Facilitators Entities in UAE, Tรผrkiye, China, Kyrgyzstan aiding sanctions evasion. 30+ entities
Virtual Asset Providers Crypto exchanges and fintech firms moving Russian funds. 10+ entities

EU Sanctions Packages (14th & 15th)

ยท 14th Package (June 2024): Focus on energy, LNG projects, and vessels contributing to Russia’s war effort. Extended no-road clause to prevent EU subsidiaries from using Russian software.
ยท 15th Package (Dec 2024): Targeted additional individuals and added 50+ new entities to the list, specifically addressing circumvention.

Asset Seizures & Freezes

ยท EU: โ‚ฌ1.5 billion in sanctioned Russian assets frozen in EU central banks (separate from immobilized reserves).
ยท US: Task Force KleptoCapture continued prosecutions for sanctions evasion.
ยท Oligarch Yachts: Legal battles continue over yachts seized in 2022-2023 (e.g., Fiji, Italy), with owners using offshore trusts to claim ownership.

The Russian Sovereign Assets Debate

ยท Status: Approximately $300 billion in Russian Central Bank assets remain immobilized in Western jurisdictions.
ยท 2025 Proposal: Discussions regarding using the profits (windfall taxes) from these assets to fund loans for Ukraine.

Part VII: Key Individuals Summary (2024-2025) {#part-vi}

Recently Sanctioned / Re-targeted

Name Affiliation Sanctioning Body Status
Alexander Bastrykin Investigative Committee EU, UK Sanctioned
Andrei Guryev Phosagro UK, EU Sanctioned; assets frozen
Alexei Mordashov Severstal EU Sanctions maintained
Multiple Prison Officials Federal Penitentiary Service EU Sanctioned (Navalny case)
Ismail Abdulla UAE-based Facilitator OFAC Sanctioned

Awaiting Trial / Under Investigation (Evasion Cases)

Name/Entity Role Status
Various Cypriot Law Firms Facilitating trust structures Under EU scrutiny
Dubai Real Estate Brokers Selling luxury property to sanctioned individuals Under US investigation

Summary Statistics {#summary}

Category Count / Value
Navalny-Related Designations (EU) 33 Individuals
Vessels Sanctioned (Shadow Fleet) 50+
Third-Country Facilitators Designated 30+ Entities
Russian Central Bank Assets Immobilized ~$300 Billion
Major Oligarchs with ICIJ Links 15+
Total New Entities/Individuals (2024-2025) 200+

Sources

  1. U.S. Department of the Treasury, OFAC: https://ofac.treasury.gov/
  2. European Union External Action Service: https://www.eeas.europa.eu/
  3. UK His Majesty’s Treasury: https://www.gov.uk/government/organisations/hm-treasury
  4. International Consortium of Investigative Journalists (ICIJ): https://www.icij.org/
  5. The Atlantic Council’s Russia Sanctions Database: https://www.atlanticcouncil.org/
  6. Cyprus Confidential / ICIJ: https://www.icij.org/investigations/cyprus-confidential/

โฌ† Back to Offshore Index Project Hub โฌ†

Report Date: March 10, 2026
Data Sources: OFAC, EU External Action Service, UK Treasury, ICIJ, Atlantic Council, Federal Court Filings.



Bernd Pulch โ€” Bio
Bernd Pulch โ€” Bio Photo

Bernd Pulch (M.A.) is a forensic expert, founder of Aristotle AI, entrepreneur, political commentator, satirist, and investigative journalist covering lawfare, media control, investment, real estate, and geopolitics. His work examines how legal systems are weaponized, how capital flows shape policy, how artificial intelligence concentrates power, and what democracy loses when courts and markets become battlefields. Active in the German and international media landscape, his analyses appear regularly on this platform.

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