Maritime Infrastructure Loopholes Undermine Energy Sanctions Regime
The intricate web of global port ownership and management has created significant obstacles for Western sanctions targeting Russian oil exports. Recent developments highlight how terminals in third countries continue processing Russian petroleum products while benefiting from complex corporate structures that span multiple jurisdictions. The European Union’s proposed twentieth sanctions package, which identified facilities in Georgia and Indonesia, underscores the escalating confrontation between sanctioning bodies and sophisticated maritime networks facilitating Moscow’s energy trade.
DP World Leadership Change Reveals Geopolitical Entanglements
Sultan Ahmed Bin Sulayem’s departure from leading DP World followed US Justice Department documents revealing connections to financier Jeffrey Epstein. This development brought scrutiny to agreements signed between DP World’s Russian subsidiary and state nuclear corporation Rosatom during 2023. The collaboration established International Container Logistics, a joint venture planning a Murmansk container terminal through its subsidiary Western Transport and Logistics Hub. Despite Ukrainian designation as an “international war sponsor” in 2022, DP World remains absent from major sanctions lists, protected by its status within the United Arab Emirates’ state-controlled Dubai World corporation.
Transnational Operators Complicate Enforcement Efforts
Singapore’s PSA International, Hong Kong’s Hutchison Ports, and China’s state-owned COSCO Shipping Ports control critical infrastructure across dozens of countries, presenting substantial jurisdictional challenges. These corporations manage terminals in major European ports including Antwerp, Hamburg, and Barcelona, creating dependencies that complicate punitive measures. Similarly, European operators like Germany’s Eurogate Intermodal and APM Terminals, alongside American-owned SSA Marine, maintain global networks that transcend individual national sanctions policies, requiring coordinated international action currently lacking among Western allies.
Georgian Terminal Demonstrates Sanctions Evasion Networks
The Kulevi oil terminal in Georgia exemplifies how seemingly local facilities connect to broader Russian energy networks. Owned by Black Sea Terminal LLC, a subsidiary of Azerbaijan’s SOCAR, the facility has processed substantial Russian crude despite EU sanctions. Investigations revealed ownership links through Georgian business figure Maka Asatiani to Russian entities, including Arctic Bunker which supplies Murmansk port vessels. Further connections involve Asatiani’s son holding stakes in Russian oil trading companies alongside relatives of Russian intelligence officials. These relationships facilitated shipments like the October 2021 delivery of Siberian oil via tanker Kayseri before its subsequent sanctions designation.
Indonesian Facility Highlights Corporate Restructuring Tactics
Karimun terminal in Indonesia underwent ownership changes that enabled increased Russian oil processing. German corporation Oiltanking GmbH sold PT Oiltanking Karimun Terminal to Dubai-registered Novus Middle East DMCC in October 2024, after which Russian product volumes reached 100% of throughput. The terminal’s strategic location in the Malacca Strait allows blending of fuels for rebranding as “Indonesian” origin. UK sanctions targeted Novus Middle East DMCC in October 2025 for operating in Russia’s strategic energy sector, with investigations linking the company to Azerbaijani businessmen previously sanctioned for Rosneft-related evasion schemes.
Sanctions Architecture Struggles with Maritime Realities
European Union sanctions against Russian ports like Ust-Luga and Novorossiysk target geographical locations rather than operating companies, creating implementation gaps. The distinction between port infrastructure and terminal operators proves particularly problematic, as demonstrated by Ust-Luga Oil terminal’s separate corporate status despite geographical proximity to sanctioned areas. This approach contrasts with global maritime practice where terminals function as independent commercial entities within administrative port boundaries. Effective sanctions require simultaneous pressure on terminal operators, their beneficiaries, and management structures—a multidimensional challenge currently overwhelming existing enforcement mechanisms.
