Sanctions/enforcement
Updated
Summary
This indicator measures how hard sanctions on Iranian and Russian oil and gas are enforced, against how much is licensed away. Enforcement means designations: putting tankers, shipping firms, refineries, traders and banks on blacklists such as the US Treasury's SDN List, which cuts them off from dollars and Western services. Licensing means general licenses (GLs), blanket permissions that let otherwise-banned trade happen, usually for a set period. AA reads the indicator from OFAC, State, EU and UK actions, and checks it against official volume data such as IEA supply estimates.
Key numbers
EU-listed Russian shadow-fleet vessels: 673 (as of 2026-07-23). Source: consilium.europa.eu
UK-sanctioned shadow-fleet tankers (UK total): over 600 (as of 2026-10-08). Source: gov.uk
Vessels added to SDN List in OFAC's largest recent Iran action: 22 (2 delisted) (as of 2026-10-08). Source: ofac.treasury.gov
Iran-related persons, vessels and aircraft sanctioned by OFAC since Feb 2025: over 1,000 (as of 2026-04-24). Source: home.treasury.gov
China's share of Iran's oil exports (Treasury estimate): about 90% (as of 2026-04-28). Source: home.treasury.gov
Iranian crude supply (IEA): 1.94 mb/d (Sep 2026) (as of 2026-10-14). Source: iea.org
Russian crude supply vs implied OPEC+ target (IEA): 8.43 mb/d, 1.52 mb/d below target (Sep 2026) (as of 2026-10-14). Source: iea.org
Middle East + Russia net diesel/gasoil exports (IEA): 820 kb/d (Sep 2026), down >60% y/y (as of 2026-10-14). Source: iea.org
EU price cap on Russian crude: $44.10/bbl from 2026-02-01; automatic adjustment paused to 2027-07-15 (as of 2026-07-23). Source: finance.ec.europa.eu
OFAC GL 135 (Russian diesel) expiry: 12:01 a.m. EDT 2027-04-07 (as of 2026-10-09). Source: ofac.treasury.gov
Graham Act tariffs in force: 0 of 3 (all waived, no end date) (as of 2026-10-16). Source: whitehouse.gov
Timeline
2026-10-16 — President's order waives all Graham Act tariffs (500% on Russian goods; 100% on top Russian oil/gas importers and evasion facilitators) and most of its new sanctions; pre-existing Russia sanctions unchanged. (Source: whitehouse.gov)
2026-10-15 — OFAC designates 16 individuals and 10 entities in Iran financial and charity networks; extends Lukoil carve-outs (GL 128D to 2027-04-24; GL 130B). (Source: ofac.treasury.gov)
2026-10-09 — OFAC issues GL 135 authorizing Russian-origin diesel sales and imports, including into the US, until 2027-04-07. (Source: ofac.treasury.gov)
2026-10-08 — OFAC adds 22 vessels, 27 entities and 6 individuals under Iran authorities; Treasury says the remaining Iranian shadow-fleet network is largely neutralized. UK sanctions 12 more tankers the same day. (Source: ofac.treasury.gov)
2026-09-18 — Graham Sanctioning Russia and Iran Act of 2026 becomes law (per the 2026-10-16 order); most provisions were due 2026-10-18. (Source: whitehouse.gov)
2026-08-24 — Treasury launches Operation Economic Outcast against Iran with nearly 60 designations and five blocked shadow-fleet vessels. (Source: home.treasury.gov)
2026-07-29 — OFAC designates 10 entities and 8 vessels under E.O. 13902. (Source: ofac.treasury.gov)
2026-07-23 — EU 21st package: 41 more vessels (673 total), refinery transaction bans in third countries, price-cap auto-adjustment paused to July 2027. (Source: consilium.europa.eu)
2026-07-07 — OFAC revokes Iran GL X six weeks early; GL X1 allows wind-down only, to 2026-07-17. (Source: ofac.treasury.gov)
2026-06-22 — OFAC posts Iran GL X (dated 2026-06-21) authorizing Iranian crude and product sales until 2026-08-21. (Source: ofac.treasury.gov)
2026-06-17 — Russia GL 134C, the last of the loaded-cargo waivers found, expires. (Source: ofac.treasury.gov)
2026-04-28 — OFAC alert warns banks about Chinese teapot refineries buying Iranian crude. (Source: home.treasury.gov)
2026-04-24 — OFAC designates Hengli (Dalian) refinery and 19 tankers. (Source: home.treasury.gov)
2026-04-23 — EU 20th package: 46 vessels added (632 total); legal basis for a future maritime services ban. (Source: finance.ec.europa.eu)
2026-03-20 — OFAC Iran GL U lets cargoes loaded by 2026-03-20 be sold until 2026-04-19. (Source: ofac.treasury.gov)
2026-03-19 — OFAC Russia GL 134A (replacing GL 134 of 2026-03-12) lets cargoes loaded by 2026-03-12 be sold until 2026-04-11; later extended by 134B and 134C. (Source: ofac.treasury.gov)
2026-01-23 — OFAC designates 8 entities and 9 vessels tied to Iranian oil. (Source: ofac.treasury.gov)
2026-01-15 — EU dynamic mechanism lowers Russian crude price cap to $44.10 from 2026-02-01. (Source: finance.ec.europa.eu)
2025-10-23 — EU 19th package adds 117 vessels to the port-access ban list. (Source: consilium.europa.eu)
2025-10-22 — Treasury designates Rosneft, Lukoil and 34 subsidiaries. (Source: home.treasury.gov)
Key actors and links
U.S. Treasury (actor:us-treasury): OFAC and Treasury issue the designations, general licenses and alerts that make up most of this indicator's US readings.
U.S. Department of State (actor:us-department-of-state): Designates under E.O. 13846 in joint Iran actions; its own fact sheets could not be fetched in this pass.
European Union (actor:european-union): Lists shadow-fleet vessels (673 by July 2026), sets the dynamic price cap and refinery transaction bans.
United Kingdom (country:united-kingdom): Has sanctioned over 600 tankers and says it covers over 90% of Russian oil production capacity.
Iran (country:iran): Target of the US enforcement campaign (Operation Economic Outcast); licenses U and X briefly eased it in 2026.
Russia (country:russia): Target of oil sanctions; US enforcement now mixes Rosneft/Lukoil blocking with carve-outs such as GL 135.
China (country:china): Treasury says it buys about 90% of Iran's oil exports, mainly via Shandong teapot refineries.
India (country:india): Large buyer of Russian crude; potential target of the now-waived Graham Act importer tariff (inference: the Act names no country).
Iranian oil exports (commodity:iranian-oil-exports): The flow that Iran enforcement actions try to shrink; IEA reports production, not exports.
Sanctions on Russia (policy:russia-sanctions): The overall Russia regime; this node tracks only its energy enforcement intensity.
Refined products (commodity:diesel): GL 135 targets Russian diesel; IEA says Middle East and Russian diesel exports are down more than 60%.
2026 Iran war (event:2026-iran-war): The war drove both the 2026 oil carve-outs (GL U, GL X, GL 134 series) and the later enforcement surge.
Strait of Hormuz (place:strait-of-hormuz): EU cited the Hormuz closure when pausing price-cap adjustments; supply stress weighs against strict enforcement.
Freight (market:tanker-freight): Shadow-fleet listings remove tankers from usable trade, a channel into freight rates (inference).
Russia–Ukraine war (theme:russia-ukraine-war): Ukrainian refinery strikes, not sanctions, are IEA's stated cause of the Russian product-export collapse.
Why it matters now
In 2026 the US ran two opposite policies at once. When the Iran war spiked oil prices, OFAC licensed sanctioned barrels back into the market: GL U for Iranian cargoes, the GL 134 series for Russian cargoes (through 2026-06-17), and GL X, a broad Iran oil license dated 2026-06-21. Then the direction flipped for Iran. OFAC revoked GL X on 2026-07-07, Treasury launched Operation Economic Outcast on 2026-08-24, and on 2026-10-08 OFAC added 22 vessels in one action. The mechanism is simple: a designated tanker loses insurers, ports and buyers who need dollar access, so it carries less or carries at a steeper discount. IEA data show Iranian crude supply at 1.94 mb/d in September, down from 2.72 mb/d in July. UNKNOWN: how much of that drop is enforcement and how much is war damage or the breakdown of the mid-June ceasefire, which IEA cites.
For Russia the signal points the other way. OFAC issued GL 135 on 2026-10-09, letting Russian diesel be sold, including into the US, until 2027-04-07. On 2026-10-16 the President waived every Graham Act tariff, including a 100% duty on the largest buyers of Russian oil and gas, and most of its new sanctions, with no end date. The EU paused its price-cap adjustment, citing Hormuz. Europe and the UK still add tankers (673 and over 600). Inference (AA): when product markets are tight, US policy trades enforcement for supply. IEA adds a caution. It says Russia's diesel exports are limited by damaged refineries, so easing restrictions is unlikely to change the balance much. A license only permits trade. It does not prove barrels move.
Risks and open questions
Bull case: The case that energy sanctions enforcement is strengthening and matters more: OFAC has run a steady Iran campaign since August 2026, with 22 vessels in one action on 2026-10-08 and Treasury's claim that the remaining shadow fleet is largely neutralized. It has moved beyond tankers to refineries (Hengli) and banks (the teapot alert, Turkish financial firms). GL X was revoked six weeks early, which shows licenses can be pulled fast. Europe and the UK keep adding vessels (673 EU, over 600 UK) and now reach third-country refineries and traders. IEA data show Iranian crude supply falling from 2.72 mb/d in July to 1.94 mb/d in September. Inference (AA): if that decline reflects enforcement and not only war damage, the indicator is biting on Iran.
Bear case: The case that enforcement is weakening or matters less: the US has repeatedly licensed sanctioned oil back into the market when prices spiked (GL U, the GL 134 series, GL X, now GL 135 for Russian diesel). The 2026-10-16 order waived every Graham Act tariff and most of its new sanctions with no end date. The EU paused its price-cap mechanism. Lukoil carve-outs keep getting extended. On Russia, IEA attributes the product-export collapse to Ukrainian drone damage and Russia's own export bans, not sanctions, so this indicator may explain little of the volume change. Inference (AA): enforcement is selective, hard on Iran and soft on Russia, and the selection follows oil prices and diplomacy.
Falsifiers: - OFAC issues a new broad Iran oil general license or a GL X-style authorization: falsifies 'Iran enforcement is tightening'. - The administration revokes the Graham Act waivers or imposes the importer tariff: falsifies 'Russia enforcement is being held off'. - OFAC designates major Russian shadow-fleet tankers or Chinese/Indian buyers of Russian crude at scale: falsifies the Iran-hard, Russia-soft reading. - IEA reports Iranian supply recovering toward 2.5 mb/d or more while designations continue: weakens the claim that designations cut volumes. - Russian product exports recover with refinery repairs despite sanctions: confirms that sanctions are not the binding constraint on Russian products. - GL 135 expires on 2027-04-07 without renewal, or is revoked early: falsifies 'diesel carve-out is open-ended'.
What to watch
GL 131J (Lukoil International divestment) authorization end date (2026-10-22); Source: ofac.treasury.gov
IEA November Oil Market Report: Iranian and Russian supply, diesel exports (no scheduled date); Source: iea.org
USTR monitoring of Russian oil purchases under the 2026-10-16 order; any revisit of the waivers (no scheduled date); Source: whitehouse.gov
Further Operation Economic Outcast designations of Iranian tankers, refineries or banks (no scheduled date); speculative, no scheduled source
EU interim review of the price-cap pause and Council decision on the maritime services ban (by 2027-07-15); Source: consilium.europa.eu
OFAC GL 135 Russian diesel license expiry or renewal (2027-04-07); Source: ofac.treasury.gov
Any vessel-tracking or official data showing Russian diesel actually moving under GL 135 (no scheduled date); speculative, no scheduled source
AA inference
Inference (AA): This indicator is best read as a balance, not a count. On one side sit designations, alerts and revocations; on the other, general licenses and waivers. In late 2026 the balance has split by country: tight on Iran, loose on Russia. The causal chain AA tracks is oil-price stress, then US licensing or waivers, then more sanctioned barrels or products allowed to reach market, then some relief for diesel and Brent. The reverse chain also runs. Lower prices make room for tougher enforcement. The weak link is measurement. Official sources publish actions, not delivered volumes, so AA treats the volume effect as UNKNOWN unless IEA or another official source shows it.
Sources
On 2026-10-16 the President signed an order implementing the Lindsey O. Graham Sanctioning Russia and Iran Act of 2026, which the order says became law on 2026-09-18. Section 4 waives the Act's duties under sections 112 and 113 and its sanctions in sections 102(a), 102(d), 102(e), 103 through 111 and 117. (Source: whitehouse.gov, accessed 2026-10-17)
The waived tariffs were a 500% ad valorem increase on Russian-origin goods, a 100% increase on the five largest importers of Russian crude oil and natural gas that knowingly make new purchases on or after 2026-10-18, and a 100% increase on the top five facilitators of Russian oil sanctions evasion. (Source: whitehouse.gov, accessed 2026-10-17)
The 2026-10-16 order says it does not affect measures under the Russia-related national emergency (continued 2026-03-24) as in effect the day before enactment, sets no expiry for the waivers, and directs the US Trade Representative to monitor Russian oil and gas purchases and evasion facilitation and to report to the President. (Source: whitehouse.gov, accessed 2026-10-17)
On 2026-10-15 OFAC added 16 individuals and 10 entities under the Iran program (E.O. 13902) and one Cuba-related entity, with no vessels, and issued Russia-related GLs 128D and 130B (Lukoil retail stations abroad; Lukoil entities in Bulgaria) and Iran GL FF. (Source: ofac.treasury.gov, accessed 2026-10-17)
OFAC FAQ 1225, updated 2026-10-15, says GL 128D extends authorization for Lukoil retail service stations outside Russia to 2027-04-24 and GL 131J extends authorization for divesting Lukoil International GmbH's non-Russian assets to 2026-10-22. (Source: ofac.treasury.gov, accessed 2026-10-17)
On 2026-10-09 OFAC issued Russia-related General License 135, authorizing transactions related to the sale, delivery, offloading and importation of Russian-origin diesel fuel, including into the United States, otherwise barred by 31 CFR parts 587 and 589, through 12:01 a.m. EDT on 2027-04-07. (Source: ofac.treasury.gov, accessed 2026-10-17)
GL 135 does not authorize debits to accounts at US financial institutions of the Central Bank of the Russian Federation, the National Wealth Fund or the Ministry of Finance. (Source: ofac.treasury.gov, accessed 2026-10-17)
On 2026-10-08 OFAC added 6 individuals, 27 entities and 22 vessels under the Iran program (10 entities and 5 vessels tagged E.O. 13846; 17 entities and 17 vessels tagged E.O. 13902) and removed 2 vessels, HAKUNA MATATA and PINOCCHIO. (Source: ofac.treasury.gov, accessed 2026-10-17)
Treasury's 2026-10-08 release says the 17-vessel action 'effectively neutralizes' the vast majority of Iran's remaining shadow fleet network; it gives no total fleet size or cumulative count. Treasury Secretary Bessent said no enabler of Iranian sanctions evasion is safe. (Source: home.treasury.gov, accessed 2026-10-17)
Treasury launched Operation Economic Outcast on 2026-08-24, calling it 'Economic D-Day'; that day OFAC designated nearly 60 entities, individuals and vessels, identified five shadow-fleet vessels as blocked property and made five sectoral determinations under E.O. 13902. (Source: home.treasury.gov, accessed 2026-10-17)
On 2026-09-04 OFAC designated three Istanbul-based Golden Global financial entities under E.O. 13902 and issued wind-down Iran GL CC. (Source: ofac.treasury.gov, accessed 2026-10-17)
On 2026-07-29 OFAC designated 10 entities and 8 vessels under E.O. 13902. (Source: ofac.treasury.gov, accessed 2026-10-17)
On 2026-07-07 OFAC revoked Iran General License X and replaced it with GL X1, which authorizes only wind-down activities through 12:01 a.m. EDT on 2026-07-17 and does not authorize new purchases or loadings of Iranian-origin products on or after 2026-07-07. (Source: ofac.treasury.gov, accessed 2026-10-17)
Iran General License X, dated 2026-06-21 and posted by OFAC on 2026-06-22, authorized the production, delivery and sale of Iranian-origin crude oil, petrochemical products and petroleum products until 2026-08-21. (Source: ofac.treasury.gov, accessed 2026-10-17)
Russia-related GL 134C, issued 2026-05-18, authorized delivery and sale of Russian-origin crude and petroleum products loaded on or before 2026-04-17, through 12:01 a.m. EDT on 2026-06-17; it replaced GL 134B (issued 2026-04-17, expired 2026-05-16). (Source: ofac.treasury.gov, accessed 2026-10-17)
Russia-related GL 134A, issued 2026-03-19, replaced GL 134 (dated 2026-03-12) and authorized delivery and sale of Russian-origin crude and products loaded by 12:01 a.m. EDT on 2026-03-12, through 2026-04-11. (Source: ofac.treasury.gov, accessed 2026-10-17)
Iran General License U, issued 2026-03-20, authorized delivery and sale of Iranian-origin crude and petroleum products loaded on or before 12:01 a.m. EDT on 2026-03-20, through 2026-04-19, including on blocked vessels. (Source: ofac.treasury.gov, accessed 2026-10-17)
On 2026-04-28 OFAC issued an alert warning financial institutions about China-based independent 'teapot' refineries, mainly in Shandong; Treasury says China buys about 90% of Iran's oil exports and teapots account for most of those imports. (Source: home.treasury.gov, accessed 2026-10-17)
On 2026-04-24 OFAC designated China-based Hengli Petrochemical (Dalian) Refinery and 19 shadow-fleet tankers; Treasury said OFAC had sanctioned over 1,000 Iran-related persons, vessels and aircraft since February 2025. (Source: home.treasury.gov, accessed 2026-10-17)
On 2026-01-23 OFAC designated 8 entities and 9 vessels under E.O. 13902 and issued Iran GL T for limited safety, environmental and cargo-offloading transactions. (Source: ofac.treasury.gov, accessed 2026-10-17)
On 2025-10-22 Treasury designated Rosneft and Lukoil, Russia's two largest oil companies, and 34 Russia-based subsidiaries under E.O. 14024. (Source: home.treasury.gov, accessed 2026-10-17)
The EU's 21st package (2026-07-23) listed 41 more shadow-fleet vessels, bringing the EU total to 673, and paused the automatic adjustment of the Russian crude price cap until 2027-07-15. (Source: consilium.europa.eu, accessed 2026-10-17)
The 21st package also enabled transaction bans on refineries in Russia and third countries that process Russian crude or products, and added 5 oil traders to the transaction-ban list. (Source: consilium.europa.eu, accessed 2026-10-17)
The EU's 20th package (2026-04-23) added 46 vessels and delisted 11, for 632 listed vessels, and set a legal basis for a future maritime services ban on Russian oil whose entry into force the Council will decide. (Source: finance.ec.europa.eu, accessed 2026-10-17)
The EU's 19th package (2025-10-23) added 117 vessels to the port-access ban list. (Source: consilium.europa.eu, accessed 2026-10-17)
The European Commission set the Russian crude price cap at $44.10 per barrel effective 2026-02-01, 15% below the average Urals market price over a 22-week reference period. (Source: finance.ec.europa.eu, accessed 2026-10-17)
The UK said on 2026-10-08 that it sanctioned 12 more tankers, bringing its total to over 600, plus Zarubezhneft and INK Capital, and that UK sanctions now cover over 90% of Russia's oil production capacity. (Source: gov.uk, accessed 2026-10-17)
IEA's October 2026 Oil Market Report (2026-10-14) puts Russian crude supply at 8.43 mb/d in September, 1.52 mb/d below its implied OPEC+ target, and Iranian crude supply at 1.94 mb/d, against sustainable capacity of 3.8 mb/d. (Source: iea.org, accessed 2026-10-17)
IEA says combined Middle East and Russian net diesel/gasoil exports fell to 820 kb/d in September 2026, down more than 60% year on year, and that the recently announced easing of Russian diesel export restrictions is unlikely to materially alter the balance because of a lack of operational Russian refinery capacity. (Source: iea.org, accessed 2026-10-17)
IEA's 2026-09-17 commentary says Russian refinery throughput fell to 3.8 mb/d in June 2026, its lowest in more than 20 years, after Ukrainian attacks, and that Russia imposed its first-ever diesel export ban on 2026-07-08. (Source: iea.org, accessed 2026-10-17)
IEA's 2026-09-17 commentary says Russia's January-August 2026 fiscal revenues were almost 17% below a year earlier at RUB 5 trillion. (Source: iea.org, accessed 2026-10-17)
IEA's September 2026 Oil Market Report (2026-09-11) puts Iranian crude supply at 2.72 mb/d in July and 2.16 mb/d in August 2026, and cites a continuing impasse in US-Iran negotiations. (Source: iea.org, accessed 2026-10-17)
IEA's August 2026 Oil Market Report links a July Iranian supply setback to the breakdown of the mid-June Iran-US ceasefire agreement. (Source: iea.org, accessed 2026-10-17)