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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

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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:

· 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.

  1. 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.

  1. 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.

  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)

· 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.

  1. 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.

  1. 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.

  1. 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

  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/

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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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