The Russia Offshore & Sanctions Index: 2024-2025 Update

THE OFFSHORE INDEX PROJECT HUB

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

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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:

· Expanded Sectoral Sanctions: Targeting remaining Russian financial institutions, energy exports, and technology imports.
· Focus on Evasion Networks: Disruption of third-country facilitators, particularly in the UAE, Türkiye, and Eurasia, using shell companies and virtual assets.
· Navalny-Related Designations: Posthumous and ongoing sanctions against individuals linked to the imprisonment and death of Alexei Navalny.
· 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.

Andrei Guryev & Family (Phosagro)

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

Alexei Mordashov (Severstal)

· Connection: Primary beneficiary of Severstal, a major Russian steel and mining company.
· 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.
· Offshore Links: Extensive use of Cypriot holding companies (e.g., Rayglow Ltd.) to own international assets, as documented in the Cyprus Confidential leaks.
· Status: Sanctioned; legal battles over seized assets ongoing.

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

Other Key Designations (2024-2025)

· Military Leadership: Continued sanctions against high-ranking military staff involved in the ongoing conflict.
· Regional Governors: Asset freezes on officials in occupied territories of Ukraine.
· 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.

Virtual Asset Service Providers (VASPs)

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

Türkiye & UAE Transshipment Hubs

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

The “Shadow Fleet” of Oil Tankers

· Target: OFAC and the UK added dozens of individual tankers to the sanctions list.
· Method: Aging vessels with opaque ownership (often registered in Liberia, Marshall Islands, or Panama) used to transport Russian crude above the G7 price cap.
· 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

· Severstal: Complex ownership via Cyprus.
· Phosagro: Shareholder structures involving Jersey and Cyprus.
· Lukoil: Historically used Dutch and Cypriot holding companies.
· 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, Türkiye, 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)

· 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.
· 15th Package (Dec 2024): Targeted additional individuals and added 50+ new entities to the list, specifically addressing circumvention.

Asset Seizures & Freezes

· EU: €1.5 billion in sanctioned Russian assets frozen in EU central banks (separate from immobilized reserves).
· US: Task Force KleptoCapture continued prosecutions for sanctions evasion.
· 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

· Status: Approximately $300 billion in Russian Central Bank assets remain immobilized in Western jurisdictions.
· 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

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

⬆ Back to Offshore Index Project Hub ⬆

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

Bernd Pulch — Bio
Bernd Pulch — 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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The U.S. Offshore & Financial Crime Index: 2026 Update

THE OFFSHORE INDEX PROJECT HUB

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The U.S. Offshore & Financial Crime Index: 2026 Update

Date: February 15, 2026
Source Compilation: Public Records, DOJ, IRS-CI, OFAC, FinCEN, ICIJ

Executive Summary

This report provides a structured overview of newly documented offshore-linked financial crime cases and enforcement actions connected to the United States between 2024 and early 2026. The data integrates official sources including the Department of Justice (DOJ), IRS Criminal Investigation (IRS-CI), Office of Foreign Assets Control (OFAC), Financial Crimes Enforcement Network (FinCEN), and the ICIJ Offshore Leaks database.

Key Trends:

· Cryptocurrency as a Vector: Significant prosecutions of mixing services (Samourai Wallet) and scam laundering (Daren Li) show increased scrutiny of digital assets.
· Transnational Crime: The designation of the Cambodia-based Prince Group as a Transnational Criminal Organization (TCO) highlights the scale of online fraud targeting Americans.
· Foreign Influence: High-profile cases like that of former NY aide Linda Sun underscore efforts to combat undisclosed foreign influence and money laundering.
· Regulatory Surge: DOJ sanctions prosecutions nearly doubled from 2023 to 2024, and FinCEN continues aggressive enforcement across traditional and crypto financial sectors.

Part I: Cryptocurrency Laundering Networks

Samourai Wallet: Crypto Mixing Service Prosecuted

The founders of Samourai Wallet, a cryptocurrency mixing service designed to obfuscate transactions, were sentenced in late 2025 for laundering over $2 billion, including hundreds of millions in criminal proceeds.

· Entity: Samourai Wallet
· Founders: Keonne Rodriguez (CEO), William Lonergan Hill (CTO)
· Platform Functions: “Whirlpool” (mixing), “Ricochet” (obfuscation)
· Criminal Sources Laundered: Drug trafficking, darknet marketplaces, cyber intrusions, fraud schemes, sanctioned jurisdictions, and murder-for-hire schemes.
· Financial Impact:
· Total Processed: Over $2 billion
· Criminal Proceeds Identified: $237+ million
· Forfeiture Order: $237,832,360.55
· Sentencing (November 2025):
· Keonne Rodriguez: 5 years prison, $250,000 fine.
· William Lonergan Hill: 4 years prison, $250,000 fine.
· Source: IRS – Samourai Wallet Founders Sentenced

AML Bitcoin: Fraudulent Cryptocurrency Scheme

The founder of “AML Bitcoin” was sentenced for defrauding investors with false claims about the cryptocurrency’s technology.

· Founder/CEO: Rowland Marcus Andrade
· Charges: Wire fraud, money laundering
· Court Outcome: Convicted March 2025; Sentenced July 29, 2025, to 7 years (84 months) federal prison.
· Scheme: Raised millions through false and misleading statements to investors about the company’s technology.
· Source: IRS – AML Bitcoin Sentencing

Daren Li: Laundering for Pig-Butchering Scams

A dual Chinese and St. Kitts & Nevis national was sentenced to 20 years for orchestrating the industrial-scale laundering of proceeds from “pig-butchering” cryptocurrency investment scams.

· Defendant: Daren Li (Age 41)
· Scheme: Pig-butchering cryptocurrency fraud.
· Financial Scale: $74 million laundered.
· Methodology: Nearly $60 million was funneled through U.S.-based shell companies and converted to cryptocurrency.
· Sentence: 20 years federal prison (Plea: November 12, 2024).
· Source: TRM Labs – Daren Li Sentencing

Part II: Foreign Influence & Political Corruption

Linda Sun: Chinese Government Influence Operation

A former high-ranking New York state aide’s trial for acting as an unregistered agent of the Chinese government ended in a mistrial, with prosecutors seeking a retrial.

· Primary Individual: Linda Sun
· Role: Former Deputy Chief of Staff to NY Gov. Kathy Hochul; Deputy Diversity Officer under Gov. Andrew Cuomo.
· Background: Naturalized U.S. citizen, born in Nanjing, China.
· Spouse/Co-Conspirator: Chris Hu (Charged with money laundering, bank fraud, tax evasion).
· Charges: Originally 8 counts, expanded via superseding indictments (Feb & June 2025) to 19 counts, including foreign agent conspiracy, visa fraud, money laundering, wire fraud, and bribery.
· Alleged Benefits from Chinese Government:
· Millions of dollars in payments.
· All-expenses-paid trips to China.
· VIP tickets to events.
· Gifts, including Nanjing-style salted ducks.
· Assets Seized:
· Long Island home.
· Hawaii condominium ($1.9 million).
· Ferrari and other luxury cars.
· Case Status: Arrested September 3, 2024. Trial in late 2025 ended in a mistrial (hung jury). Prosecutors are seeking a retrial.
· Sources: AP News, NBC News

Part III: Transnational Criminal Organizations (TCOs)

Prince Group: Cambodia-Based Scam Network Sanctioned

In October 2025, the U.S. designated Prince Holding Group, a conglomerate based in Cambodia, and its leader as a Transnational Criminal Organization for its role in large-scale online fraud and human trafficking.

· Organization: Prince Group (Prince Holding Group)
· Leader: Chen Zhi (aka “Duke”)
· DOB: December 16, 1987
· POB: Fujian, China
· Citizenships: Cambodia, Vanuatu, Cyprus
· U.S. Actions (October 14, 2025):
· OFAC Sanctions: 146 persons and entities designated.
· FinCEN Section 311: Huione Group severed from the U.S. financial system.
· UK Sanctions: Coordinated action on 6 entities and 6 individuals.
· Financial Impact:
· Americans lost to online scams in 2024: $16.6 billion (approx. $10 billion tied to SE Asia).
· Singapore asset seizure: S$150 million ($115.9 million).
· Hong Kong frozen assets: HK$2.75 billion ($354 million).
· Taiwan seized assets: T$4.5 billion ($147.09 million).
· Criminal Activities: “Pig-butchering” investment fraud, illegal online gambling, money laundering, sextortion, forced labor, human trafficking.
· Key Compounds: Jin Bei Casino and 10+ other scam compounds controlled by the group.
· Sources: Treasury.gov – TCO Designation, Steptoe – Sanctions Update

Part IV: International Money Laundering Networks

Chinese Money Laundering Organization: Drug Proceeds

A Chinese-run money laundering organization pleaded guilty in April 2025 to laundering over $92 million in drug trafficking proceeds imported from Mexico.

· Amount Laundered: $92+ million (from drug trafficking via Mexico).
· Defendants:
· Maoxuan Xia (Chinese): Money laundering conspiracy.
· Shao Neng Lin (California citizen): Money laundering conspiracy.
· Zhou Yu (Chinese): Money laundering conspiracy.
· Methodology: Used shell company bank accounts to collect and deposit drug proceeds. Xia traveled within the U.S. to move cash; Lin and Yu opened the bank accounts.
· Potential Sentences: Up to 20 years per count.
· Source: Mofo – Anti-Money Laundering Quarterly

Part V: Major Fraud & Financial Crime Cases

Hansen Helicopters: Illicit Aviation Scheme

The CEO of a Guam helicopter company was sentenced to over 33 years for running an illicit business using unregistered aircraft.

· CEO: John Walker (Hansen Helicopters Inc.)
· Sentence: 405 months (33.75 years) in prison.
· Forfeiture: $58.4 million.
· Scheme: Operation of an illicit helicopter business with unregistered/illegal aircraft.

Dallas Investment Fraud: Fictitious Businesses

A Dallas man was sentenced to 20 years for running an investment fraud scheme through fictitious businesses.

· Defendant: Rahool Amin Makani (Dallas, Texas)
· Sentence: 20 years in prison.
· Restitution: Over $14 million.
· Scheme: Investment fraud using fictitious businesses.

North Korean IT Worker Fraud Operation

An Arizona woman was sentenced for helping North Korean IT workers infiltrate over 300 U.S. companies using stolen identities.

· Defendant: Christina Marie Chapman (Arizona)
· Sentence: 102 months (8.5 years) in prison.
· Scope: 300+ U.S. companies infiltrated; identities of ~70 U.S. citizens stolen.
· Scheme: Facilitated remote employment for North Korean workers, generating revenue for the DPRK.

Pandemic Fraud: “Feeding Our Future” (Minnesota)

Listed as one of the IRS’s top cases of 2025, this case involves one of the largest pandemic relief fraud schemes in Minnesota, with multiple defendants connected to federal relief programs. (Source: IRS – Top 10 Cases 2025)

Part VI: Offshore Corporate Structures (ICIJ Data)

The ICIJ Offshore Leaks database (Panama Papers, Paradise Papers, Pandora Papers) continues to document the use of secrecy jurisdictions by corporations and individuals with U.S. connections.

Companies with U.S. Links (BVI/Cayman/Panama)

· WOOSTER BUSINESS LIMITED (BVI) -> United States
· INTERMEDIA LTD. (Cayman) -> United States
· WELLINGTON ENTERPRISES LIMITED (Cayman) -> United States
· GLOBAL BUSINESS SOLUTIONS, GROUP INC. (BVI) -> Multiple
· SOUTHWEST COMPANY CORP. (Panama) -> Brazil

Major Corporations with Offshore Structures

· APPLE: Irish subsidiaries via BVI/Cayman.
· META (Facebook): BVI entities.
· GOOGLE-ALPHABET: Holding companies.
· MICROSOFT: Patent/royalty structures.
· AMAZON: European operations.
· UBER: European holdings.
· Nike: Tax optimization structures.
· Twitter: BVI entities.

Sources: ICIJ Offshore Leaks Database, Wikipedia – Pandora Papers

Part VII: Regulatory Enforcement Trends (2024-2025)

U.S. regulatory agencies have significantly ramped up enforcement across sanctions, anti-money laundering, and foreign investment.

· OFAC Enforcement:
· 2024: 12 enforcement actions, totaling $48.8 million in penalties. Focus: Russia-related sanctions, SDN evasion.
· 2025: 14 enforcement actions (as of Feb 2026).
· DOJ Sanctions Prosecutions:
· 2023: ~38 charges filed.
· 2024: 70+ charges filed (nearly doubled).
· Notable FinCEN Enforcement Actions (2024-2025):
· PAXFUL, INC. (Dec 2025): Money Services Business (MSB) enforcement.
· BRINK’S GLOBAL SERVICES USA (Jan 2025): Money services.
· SAHARA DUNES CASINO (Oct 2024): Casino AML violations.
· TD BANK (Oct 2024): Depository institution AML failures.
· BINANCE HOLDINGS (Nov 2023): Major MSB enforcement.
· CFIUS Enforcement (2024): Penalty authority increased; stricter scrutiny of foreign investments.
· Corporate Transparency Act (CTA): Implementation of beneficial ownership reporting is ongoing but partially delayed due to litigation. New AML obligations were added in 2024 for investment advisers and non-finance real estate transactions.

Sources: Crowe – Enforcement Trends 2025, FinCEN, Treasury – CFIUS

Part VIII: Key Individuals Summary

Sentenced (2024-2025)

Name Entity/Case Sentence Status
Keonne Rodriguez Samourai Wallet 5 years In prison
William Lonergan Hill Samourai Wallet 4 years In prison
Rowland Marcus Andrade AML Bitcoin 7 years Began Oct 2025
Daren Li Crypto Scam Laundering 20 years In prison
Rahool Amin Makani Investment Fraud 20 years In prison
John Walker Hansen Helicopters 405 months (33.75 yrs) In prison
Christina Marie Chapman North Korean IT Fraud 102 months (8.5 yrs) In prison

Awaiting Trial / Pleaded Guilty

Name Charges Status
Linda Sun Foreign agent, money laundering (19 counts) Mistrial; retrial sought
Chris Hu Money laundering, bank fraud, tax evasion Mistrial; retrial sought
Maoxuan Xia Money laundering conspiracy Guilty plea (Apr 2025)
Shao Neng Lin Money laundering conspiracy Guilty plea (Apr 2025)
Zhou Yu Money laundering conspiracy Guilty plea (Apr 2025)

Sanctioned / Fugitives

Name Role Status
Chen Zhi Prince Group Leader Sanctioned (Oct 2025); Status: Arrested in Cambodia (Nov 2025)
146 Individuals/Entities Prince Group Network Sanctioned by OFAC

Summary Statistics

Category Count / Value
Major Cryptocurrency Cases 3 (Samourai, AML Bitcoin, Daren Li)
Major Foreign Influence Cases 1 (Linda Sun – 19 counts)
Transnational Criminal Organizations 1 (Prince Group – 146 sanctioned)
Money Laundering Networks 1 (Chinese drug money – $92M)
DOJ Sanctions Charges (2024) 70+
Total OFAC Actions (2024-2025) 26
Americans Lost to Scams (2024) $16.6 billion
Total New Entities/Individuals Profiled 150+

Report Date: February 15, 2026
Data Sources: U.S. Department of Justice, IRS Criminal Investigation, U.S. Treasury (OFAC), FinCEN, ICIJ Offshore Leaks Database, Federal Court Filings.

Bernd Pulch — Bio
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