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Third-Country Sanctions Monitor · India

Which Indian Firms Have the US, EU and UK Sanctioned Since 2024?

Every US, EU and UK measure since January 2024 under the Russia and Iran sanctions programmes against firms and people with an address in India, with the rules that reach India, the trade at stake and what to watch.

Version one

Official measures only, each linked to its source. A listing records what a government did; it is not a finding by this publication. Not legal advice.

Last updated 7 October 2026 · Data to 6 October 2026

Photo: The Kochi Refinery, Kochi, Kerala, 4 September 2026. Rehman Abubakr via Wikimedia Commons, CC BY-SA 4.0.

Measures since January 2024
116

US 96 · EU 14 · UK 6. Against firms 94, against people 22.

Method

Latest action
14 September 2026

US Treasury (OFAC): Added an Iran sanctions tag to the existing SDN List entry of VTB BANK PUBLIC JOINT STOCK COMPANY.

Measures in 2026
24

to 6 October 2026

Goods exports to the US, EU and UK
$180.1bn2025

40% of India’s goods exports.

UN Comtrade

Summary

Key points

  1. 1

    Since January 2024 the US, EU and UK have taken 116 measures against firms and people with an address in India: 96 by the US, 14 by the EU and 6 by the UK. 22 of them concern people.

    Measures (CSV)

  2. 2

    69 of the US measures are under its Iran programmes and 27 under its Russia programmes. 14 of the 14 EU measures and 6 of the 6 UK measures are under Russia programmes.

    Measures (CSV)

  3. 3

    The EU froze the assets of Nayara Energy in July 2025; the listing act says its refinery is 49% owned by Rosneft. The UK listed Nayara in October 2025.

    Council Implementing Regulation (EU) 2025/1476 · UK Sanctions List entry RUS3065

  4. 4

    In 2025 India sold US$180.1bn of goods to the US, the EU and the UK, 40% of its goods exports, and bought US$62.9bn of goods from Russia.

    UN Comtrade

Measures

How many measures have been taken since 2024, and by whom?

Measures against firms and people with an address in India, by the year of the measure and the authority that took it: 69 under Iran programmes, 47 under Russia programmes. Against firms 94, against people 22. A further 4 US listings made since 2024 in India were later removed by OFAC; they are not counted here and are listed in the removals file.

YearUSEUUKTotal
2024313034
2025487358
2026 (to 6 October 2026)174324
Since January 202496146116

A firm or person with addresses in two tracked countries is counted under the first address the authority lists. People are counted, not named, on this page; the official names are in the CSV.

All measures (CSV) · Listings removed since 2024 (CSV) · Method

Record

Every action since January 2024, newest first

Each entry is one official action: who took it, what it did, the firms it named, and links to the official page and press release. Filter by authority.

  1. US Treasury (OFAC)

    Added an Iran sanctions tag to the existing SDN List entry of VTB BANK PUBLIC JOINT STOCK COMPANY.

    VTB BANK PUBLIC JOINT STOCK COMPANY

    OFAC action page · Treasury press release

  2. US State Department

    Designated 4 firms and 3 people with an address in India under US Iran sanctions; OFAC added them to the SDN List.

    SADASHIVA OVERSEAS LIMITED, PRAKRUTEES INFRA IMPEX INDIA PRIVATE LIMITED, PP SOFTTECH PRIVATE LIMITED, PORTEASE PARTNERS LLP

    OFAC action page · State Department release

  3. UK government

    Designated 1 firm with an address in India on the UK Sanctions List under its Russia sanctions.

    FRION SHIP MANAGEMENT LLP

    UK Sanctions List entries (linked from each name)

  4. US Treasury (OFAC)

    Added 1 firm with an address in India to the SDN List under its Iran sanctions.

    Skiez Travels and Logistics Private Limited

    OFAC action page · Treasury press release

  5. Council of the EU

    Added 2 firms with an address in India to Annex IV of Regulation 833/2014, which restricts exports of dual-use goods and technology to them.

    Zepto Microwave and Chip Devices Assembly LLP, Falcon Toolings

    Council Regulation (EU) 2026/1848

  6. Council of the EU

    Listed 1 firm and 1 person with an address in India for an asset freeze under its Russia sanctions.

    Peninsular Maritime India Private Limited

    Council Implementing Regulation (EU) 2026/1843

  7. US Treasury (OFAC)

    Added 1 firm with an address in India to the SDN List under its Iran sanctions.

    Sea Lead Shipping Agency India Private Limited

    OFAC action page · Treasury press release

  8. US State Department

    Designated 1 firm and 1 person with an address in India under US Iran sanctions; OFAC added them to the SDN List.

    RISHABH TRIEXIM LLP

    OFAC action page · State Department release

  9. US Treasury (OFAC)

    Added 2 firms with an address in India to the SDN List under its Iran sanctions.

    HOUSE OF SHIPPING PRIVATE LIMITED, Fleet Tanqo Private Limited

    OFAC action page · Treasury press release

  10. UK government

    Designated 2 firms with an address in India on the UK Sanctions List under its Russia sanctions.

    ZEPTO MICROWAVE AND CHIP DEVICES ASSEMBLY LLP, HINIMPEX PRIVATE LIMITED

    UK Sanctions List entries (linked from each name)

  11. US State Department

    Designated 1 firm and 1 person with an address in India under US Iran sanctions; OFAC added them to the SDN List.

    ELEVATE MARINE MANAGEMENT PRIVATE LIMITED

    OFAC action page · State Department release

  12. US Treasury (OFAC)

    Added 1 firm with an address in India to the SDN List under its Iran sanctions.

    AAYAT SHIP MANAGEMENT PRIVATE LIMITED

    OFAC action page · Treasury press release

  13. US Treasury (OFAC)

    Added 3 firms with an address in India to the SDN List under its Iran sanctions.

    RUKBAT MARINE SERVICES CO, Golden Gate Ship Management, DARYA SHIPPING PRIVATE LIMITED

    OFAC action page · Treasury press release

  14. US State Department

    Designated 1 firm with an address in India under US Iran sanctions; OFAC added it to the SDN List.

    TR6 Petro India LLP

    OFAC action page · State Department release

  15. US Treasury (OFAC)

    Added 1 firm with an address in India to the SDN List under its Iran sanctions.

    RN SHIP MANAGEMENT PRIVATE LIMITED

    OFAC action page · Treasury press release

  16. US Treasury (OFAC)

    Added 1 firm with an address in India to the SDN List under its Iran sanctions.

    Farmlane Private Limited

    OFAC action page · Treasury press release

  17. Council of the EU

    Added 3 firms with an address in India to Annex IV of Regulation 833/2014, which restricts exports of dual-use goods and technology to them.

    Shree Enterprises, Ascend Aviation India Private Limited, Aerotrust Aviation Private Limited

    Council Regulation (EU) 2025/2033

  18. UK government

    Designated 1 firm with an address in India on the UK Sanctions List under its Russia sanctions.

    NAYARA ENERGY LIMITED

    UK Sanctions List entries (linked from each name)

  19. US Treasury (OFAC)

    Added 1 firm and 3 people with an address in India to the SDN List under its Iran sanctions.

    VEGA STAR SHIP MANAGEMENT PRIVATE LIMITED

    OFAC action page · Treasury press release

  20. US State Department

    Designated 8 firms and 5 people with an address in India under US Iran sanctions; OFAC added them to the SDN List.

    SHIV TEXCHEM LIMITED, PAARICHEM RESOURCES LLP, MODY CHEM, INDISOL MARKETING PRIVATE LIMITED, HARESH PETROCHEM PRIVATE LIMITED, CHEMOVICK PRIVATE LIMITED, C. J. SHAH AND CO., B K SALES CORPORATION

    OFAC action page · State Department release

  21. UK government

    Designated 1 firm with an address in India on the UK Sanctions List under its Russia sanctions.

    HAYERS INFOTECH PRIVATE LIMITED

    UK Sanctions List entries (linked from each name)

  22. US Treasury (OFAC)

    Added 1 firm and 2 people with an address in India to the SDN List under its Iran sanctions.

    SHREEJI GEMS LTD

    OFAC action page · Treasury press release

  23. US State Department

    Designated 7 firms with an address in India under US Iran sanctions; OFAC added them to the SDN List.

    RAMNIKLAL S GOSALIA AND COMPANY, PERSISTENT PETROCHEM PRIVATE LIMITED, KANCHAN POLYMERS, JUPITER DYE CHEM PRIVATE LIMITED, GLOBAL INDUSTRIAL CHEMICALS LIMITED, ENSA SHIP MANAGEMENT PRIVATE LIMITED, ALCHEMICAL SOLUTIONS PRIVATE LIMITED

    OFAC action page · State Department release

  24. Council of the EU

    Listed 2 firms with an address in India for an asset freeze under its Russia sanctions.

    Nayara Energy Limited, Intershipping Services Hub Private Limited

    Council Implementing Regulation (EU) 2025/1476

  25. US State Department

    Designated 1 firm with an address in India under US Iran sanctions; OFAC added it to the SDN List.

    Sai Saburi Consulting Services Private Limited

    OFAC action page · State Department release

  26. US Treasury (OFAC)

    Added 2 people with an address in India to the SDN List under its Iran sanctions.

    OFAC action page · Treasury press release

  27. US State Department

    Designated 1 firm with an address in India under US Iran sanctions; OFAC added it to the SDN List.

    MARZIYA SHIPPING OPC PVT LTD

    OFAC action page · State Department release

  28. US Treasury (OFAC)

    Added 2 firms with an address in India to the SDN List under its Iran sanctions.

    Global Tankers Private Limited, B and P Solutions Private Limited

    OFAC action page · Treasury press release

  29. US Treasury (OFAC)

    Added 1 firm with an address in India to the SDN List under its Iran sanctions.

    LAKE VIEW SHIP MANAGEMENT PRIVATE LIMITED

    OFAC action page · Treasury press release

  30. Council of the EU

    Added 2 firms with an address in India to Annex IV of Regulation 833/2014, which restricts exports of dual-use goods and technology to them.

    Pratik Corporation, Agrim Aviation Private Limited

    Council Regulation (EU) 2025/395

  31. US Treasury (OFAC)

    Added 4 firms with an address in India to the SDN List under its Iran sanctions.

    Flux Maritime LLP, Cosmos Lines Inc, BSM MARINE LIMITED LIABILITY PARTNERSHIP, AUSTINSHIP MANAGEMENT PRIVATE LIMITED

    OFAC action page · Treasury press release

  32. UK government

    Designated 1 firm with an address in India on the UK Sanctions List under its Russia sanctions.

    INUSSIA IMPEX PRIVATE LIMITED

    UK Sanctions List entries (linked from each name)

  33. US Treasury (OFAC)

    Added 2 firms with an address in India to the SDN List under its Russia sanctions.

    TRIDENT INFINITY LIMITED, AMSHA MARITIME

    OFAC action page · Treasury press release

  34. US State Department

    Designated 2 firms with an address in India under US Russia sanctions; OFAC added them to the SDN List.

    Skyhart Management Services Private Limited, Avision Shipping Services Private Limited

    OFAC action page · State Department release

  35. US Treasury (OFAC)

    Added 1 firm with an address in India to the SDN List under its Iran sanctions.

    ATLANTIC NAVIGATION OPC PRIVATE LIMITED

    OFAC action page · Treasury press release

  36. Council of the EU

    Added 1 firm with an address in India to Annex IV of Regulation 833/2014, which restricts exports of dual-use goods and technology to it.

    Triac Electronics Pvt. Ltd.

    Council Regulation (EU) 2024/3192

  37. US Treasury (OFAC)

    Added 3 firms with an address in India to the SDN List under its Iran sanctions.

    VISION SHIP MANAGEMENT LLP, TIGHTSHIP SHIPPING MANAGEMENT (OPC) PRIVATE LIMITED, LIGHTSHIP MANAGEMENT LTD

    OFAC action page · Treasury press release

  38. US Treasury (OFAC)

    Added 1 firm and 1 person with an address in India to the SDN List under its Russia sanctions.

    Gazprombank Joint Stock Company

    OFAC action page · Treasury press release

  39. US State Department

    Designated 4 firms and 2 people with an address in India under US Russia sanctions; OFAC added them to the SDN List.

    TMSD GLOBAL PRIVATE LIMITED, MASK TRANS, FUTREVO, ASCEND AVIATION INDIA PRIVATE LIMITED

    OFAC action page · State Department release

  40. US Treasury (OFAC)

    Added 11 firms with an address in India to the SDN List under its Russia sanctions.

    SHREYA LIFE SCIENCES PRIVATE LIMITED, SHREEGEE IMPEX PRIVATE LIMITED, SHARPLINE AUTOMATION PRIVATE LIMITED, Pointer Electronics, ORBIT FINTRADE LLP, Khushbu Honing Private Limited, KDG ENGINEERING PRIVATE LIMITED, Innovio Ventures

    and 3 more

    Emsystech, Denvas Services Private Limited, ABHAR TECHNOLOGIES AND SERVICES PRIVATE LIMITED

    OFAC action page · Treasury press release

  41. US Treasury (OFAC)

    Added 1 firm with an address in India to the SDN List under its Iran sanctions.

    Gabbaro Ship Services PVT LTD

    OFAC action page · Treasury press release

  42. US Treasury (OFAC)

    Added 2 firms with an address in India to the SDN List under its Russia sanctions.

    PLIO ENERGY CARGO SHIPPING OPC PRIVATE LIMITED, GOTIK SHIPPING CO

    OFAC action page

  43. US State Department

    Designated 2 firms with an address in India under US Russia sanctions; OFAC added them to the SDN List.

    Zara Shipholding Co, Ocean Speedstar Solutions OPC Private Limited

    OFAC action page · State Department release

  44. Council of the EU

    Added 1 firm with an address in India to Annex IV of Regulation 833/2014, which restricts exports of dual-use goods and technology to it.

    Innovio Ventures

    Council Regulation (EU) 2024/1745

  45. US Treasury (OFAC)

    Added 1 person with an address in India to the SDN List under its Iran sanctions.

    OFAC action page · Treasury press release

  46. US Treasury (OFAC)

    Added 2 firms with an address in India to the SDN List under its Iran sanctions.

    Zen Shipping & Port India Private Limited, Sea Art Ship Management OPC Private Limited

    OFAC action page · Treasury press release

  47. Council of the EU

    Added 1 firm with an address in India to Annex IV of Regulation 833/2014, which restricts exports of dual-use goods and technology to it.

    Si2 Microsystems Pvt Ltd

    Council Regulation (EU) 2024/745

Rules

Which rules reach India, and what would trigger them?

Rules that reach firms and banks in India along with every other country, and two US orders that named India alone: the 2025 duty over Russian oil, since lifted, and the order that lifted it.

RuleMade byWhat it doesHow it reaches the countryStatus on 6 October 2026
US extends Iran sector sanctions to the automotive and rail sectors (E.O. 13902)Determination under section 1(a)(i) of E.O. 13902: automotive and rail sectors of the Iranian economy (1 October 2026)Treasury (OFAC). 1 October 2026Any person determined to operate in Iran’s automotive or rail sector can be blocked, with the same further reach as other E.O. 13902 sectors: persons who knowingly engage in significant transactions for goods or services used in the sector, and foreign banks that knowingly facilitate them. The same day OFAC designated auto-parts suppliers outside Iran for operating in the automotive sector.Any person, wherever located. OFAC FAQ 831 says Iranian and non-Iranian persons operating in E.O. 13902 sectors could be sanctioned.in forceIn force since 1 October 2026. Not yet published in the Federal Register on 6 October 2026.OFAC determination (1 October 2026) · Treasury press release sb0643 (1 October 2026)
Graham Act: duties on the largest buyers of Russian crude or gas, and mandatory sanctions on foreign firmsLindsey O. Graham Sanctioning Russia and Iran Act of 2026, Division A of H.R. 5334 (Public Law 119-111), sections 102, 103, 108, 110, 113, 115, 117 and 201Congress and the President; the President imposes the first duties, and the US Trade Representative adjusts the rates and, every 180 days, redoes the top-five importer lists and imposes duties on the countries named. 18 September 2026Requires duties of up to 100% on all goods from countries that were among the five largest importers by volume of Russian crude oil, or of Russian gas, in the 12 months before 18 September 2026 and knowingly buy again from the 30th day, and from the ‘top 5 countries facilitating Russian oil sanctions evasion’, by 18 October 2026. Other sections require sanctions on foreign suppliers to Russia’s defence industry, on owners, insurers and captains of vessels used to move Russian oil or gas around sanctions, on owners of foreign ports that serve US-sanctioned vessels, and on foreign banks that conduct significant transactions with Russian state-owned banks.Any country that meets the Sec. 113 test; the Act names none. A country is exempt for gas if it took less than 15% of Russia’s gas exports and has taken significant steps to cut them (Sec. 113(d)). The sanctions sections reach foreign firms and banks anywhere.partly in forceLaw since 18 September 2026. Sec. 102(d), which keeps in force by statute the sanctions and other measures under E.O. 14024 and the other orders issued under that national emergency (among them E.O.s 14066, 14068, 14071 and 14114), as they stood on 17 September 2026, applies now; Russia sanctions under other authorities, such as the 2014 Ukraine-related orders or CAATSA, are not covered. No country had been named, no duty imposed and no designation made under the Act by 6 October 2026. The President may waive a duty after certifying to Congress that a waiver is in the national interest (Sec. 115); ending one needs a certification in a report to Congress and a congressional review of 30 days, or 60 days if the report is sent between 10 July and 7 September (Sec. 117). Division A ends on 18 September 2031.Public Law 119-111, GovInfo · Congressional Research Service, Legal Sidebar LSB11474
US Iran listing of Russia’s VTB Bank, and a warning to foreign banks that deal with itE.O. 13902, section 1(a)(i): operating in the financial sector of the Iranian economyTreasury (OFAC). 14 September 2026OFAC added an Iran listing to VTB Bank, already blocked under US Russia sanctions, for operating in Iran’s financial sector. Treasury said foreign financial institutions that keep dealing with VTB face more sanctions risk and should cut off those relationships ‘immediately’.VTB’s US list entry names a New Delhi branch and gives a New Delhi address.in forceIn force. OFAC’s lists on 5 October 2026 show no foreign bank cut off from US correspondent accounts over dealings with VTB.Treasury press release sb0629 (14 September 2026) · OFAC Recent Actions, 14 September 2026
US extends Iran sector sanctions to aviation, digital assets, gold, shipping and technology (E.O. 13902)Determination under section 1(a)(i) of E.O. 13902 (91 FR 55265, 27 August 2026)Treasury (OFAC), with the State Department. 24 August 2026Any person determined to operate in these five sectors of Iran’s economy can be blocked. Under E.O. 13902, a person who knowingly engages in a significant transaction for goods or services used in a covered sector can also be blocked, and a foreign bank that knowingly facilitates such a transaction can be barred from US correspondent or payable-through accounts.Any person, wherever located: Treasury said OFAC ‘can now sanction any person, regardless of where they are located’ in these sectors. Each target still needs its own designation.in forceIn force since 24 August 2026; no revocation or amendment found on 6 October 2026.Federal Register, Determination under E.O. 13902 (2026-17487) · Treasury press release sb0613 (24 August 2026)
EU ban on transactions with ‘Sberbank India’ and ‘India VTB’ (Article 5ad)Council Regulation (EU) 2026/1848, amending Annex XLV of Regulation (EU) No 833/2014 (Article 5ad)Council of the EU. 23 July 2026; in force 13 August 2026Article 5ad bans EU persons from any transaction with firms outside the EU listed in Annex XLV. The annex has four parts: banks and payment or crypto firms that significantly frustrate EU sanctions on Russia (Part A) or support Russia’s war (Part B); other firms that significantly frustrate the EU’s ban on Russian oil imports, its oil price cap or its measures against listed vessels (Part C); and firms that offer cross-border payment workarounds such as netting, set-off or settlement (Part D). Regulation 2026/1848 added ‘Sberbank India’ and ‘India VTB’ to Part A with effect from 13 August 2026.The two listed entities, which are named for India; EU banks and firms may not deal with them. The annex gives names only, no addresses, so these listings are shown here rather than counted as records.in forceIn force from 13 August 2026 (EUR-Lex consolidated text of 24 July 2026).Council Regulation (EU) 2026/1848, EUR-Lex · Regulation 833/2014, consolidated text, Annex XLV
UK ban on imports of oil products refined from Russian crude in third countriesThe Russia (Sanctions) (EU Exit) (Amendment) Regulations 2026 (S.I. 2026/543), regulations 46Z9E to 46Z9IUK government (FCDO); import licences from the Department for Business, Innovation, Science and Trade. 18 May 2026; in force 20 May 2026Bans importing into the UK oil products (commodity code 2710) processed in a third country from Russian crude, and related technical assistance, finance and brokering. A general trade licence (GBSAN0004) still allows diesel and jet fuel, and the government says it will end by 1 January 2027 at the latest.Refiners in any country other than the UK, the Isle of Man and Russia that process Russian crude and sell oil products to the UK, and UK importers and service providers. The instrument names no country.partly in forceIn force since 20 May 2026, except for diesel and jet fuel, which are allowed under licence GBSAN0004 until 1 January 2027 at the latest.S.I. 2026/543, legislation.gov.uk · UK government, 12 June 2026: end date for diesel and jet fuel imports
US removes the Russian-oil duty on Indian goods (E.O. 14384)Executive Order 14384 of 6 February 2026 (91 FR 6501)The President. 6 February 2026; in force 7 February 2026Ended the 25% duty of E.O. 14329 for goods entered from 12:01 a.m. EST on 7 February 2026, citing India’s commitment to stop importing Russian oil. It tells the Commerce Department to monitor whether India resumes; if Commerce finds that it has, the Secretary of State must recommend whether to take further action, including reimposing the duty.India only: products of India imported into the US. No other third country is named.in forceIn force. Its own option to reimpose the duty rests on IEEPA, which the Supreme Court held on 20 February 2026 cannot support tariffs. The Graham Act (Sec. 113) is a separate route that does not depend on IEEPA.Executive Order 14384, Federal Register · Supreme Court, Learning Resources, Inc. v. Trump (20 February 2026)
Russian crude oil price cap: $44.10 a barrel in the EU and the UK (the US cap is $60)Council Regulation (EU) No 833/2014, Article 3n and Annex XXVIII, as amended by Regulation 2025/1494 (dynamic cap), Commission Implementing Regulation 2026/124 ($44.10 from 1 February 2026) and Regulation 2026/1848 (reset suspended)European Commission and Council of the EU; the UK applies the same level. 14 January 2026; in force 1 February 2026EU persons may trade, ship, insure or finance Russian crude for third countries only if it is bought at or below the cap, $44.10 a barrel since 1 February 2026 (products: $100 or $45). The EU’s automatic six-monthly reset is suspended until 15 July 2027; by 15 January 2027 the Commission reports and the Council may set a new level.It binds EU persons and business done in the EU. Shippers, insurers, financiers and traders in third countries are reached when they use EU services; EU firms must also use best efforts to stop entities they own abroad from undermining it (Art. 8a). The US cap for its own persons remains $60.in forceIn force at $44.10 in the EU and the UK on 6 October 2026; no Commission price notice after 15 January 2026.Regulation 833/2014, consolidated text of 24 July 2026 (Article 3n, Annex XXVIII) · Commission Implementing Regulation (EU) 2026/124 · UK maritime services ban and oil price cap: industry guidance (OFSI)
25% extra US duty on goods from India over its purchases of Russian oil (E.O. 14329)Executive Order 14329 of 6 August 2025 (90 FR 38701), under the International Emergency Economic Powers Act (IEEPA)The President; duty collected by US Customs and Border Protection. 6 August 2025; in force 27 August 2025Added a 25% duty on goods of India entered from 27 August 2025, on top of other duties, because India was importing Russian oil. Goods under Section 232 actions, goods on the reciprocal-tariff exemption list (including pharmaceuticals, semiconductors, energy products, smartphones and computers) and goods already in transit were excluded.Every Indian exporter of covered goods to the US. No firm is named.liftedLifted for goods entered from 7 February 2026 by E.O. 14384. On 20 February 2026 the Supreme Court held that IEEPA does not authorise tariffs, and E.O. 14389 ended the remaining IEEPA duties. US Customs and Border Protection (CBP) takes refund claims, with interest, for duties imposed under IEEPA, this one included, through CAPE declarations in ACE. CAPE accepts only certain unliquidated entries and certain entries liquidated within the previous 80 days; it does not yet accept entries whose liquidation is final, entries under an open protest or entries on a drawback claim, which CBP says it is still evaluating for later phases.Executive Order 14329, Federal Register · Executive Order 14389, Ending Certain Tariff Actions · CBP, IEEPA Duty Refunds
EU ban on imports of fuels refined from Russian crude in third countriesCouncil Regulation (EU) 2025/1494 of 18 July 2025, inserting Article 3ma and Annex LI into Regulation (EU) No 833/2014Council of the EU. 18 July 2025; in force 21 January 2026From 21 January 2026, bans buying, importing or transferring into the EU petroleum products (CN 2710) made in a third country from Russian crude oil, and related brokering, finance and insurance. Importers must show where the crude came from, except for products from the partner countries in Annex LI (the US, UK, Canada, Norway, Switzerland, Australia, Japan, New Zealand and Liechtenstein).It binds EU importers and EU service providers, not refiners abroad. It reaches refiners in any third country that process Russian crude and sell fuel into the EU; the Commission’s guidance sets out when a refinery that runs both Russian and other crude can still export to the EU.in forceApplies since 21 January 2026; amended by Regulations 2025/2033, 2026/506 and 2026/1848, not repealed (EUR-Lex, read 6 October 2026).Council Regulation (EU) 2025/1494, EUR-Lex · European Commission FAQ on the import ban (15 June 2026)
US sanctions risk for foreign banks that deal with Russia’s military-industrial base (E.O. 14114)Executive Order 14114 of 22 December 2023 (88 FR 89271), adding section 11 to E.O. 14024; OFAC determination under section 11(a)(ii) (89 FR 78245)The President; Treasury (OFAC). 22 December 2023Lets the Treasury cut a foreign bank off from US correspondent accounts, or block it, if it conducts or facilitates significant transactions for persons sanctioned for operating in Russia’s technology, defence, construction, aerospace or manufacturing sectors, or involving Russia’s military-industrial base. Payments in any currency are covered.Any foreign financial institution, anywhere. It has been used: Kyrgyzstan’s Keremet Bank was blocked under section 11 on 15 January 2025. In June 2024 OFAC added the foreign branch addresses of sanctioned Russian banks, including branches in New Delhi and Beijing, to their entries.in forceIn force on 6 October 2026. The national emergency behind it was continued for a year on 24 March 2026 (91 FR 15515); no revocation found.Executive Order 14114, Federal Register · Treasury press release jy2785 (Keremet Bank, 15 January 2025)

Exposure

How much trade is at stake?

Goods trade in 2025 from India’s own report to UN Comtrade, in US$ billion: what India sells to the three authorities’ markets, and its trade with Russia and Iran.

Goods trade, US$ billionExports to the worldTo the USTo the EU-27To the UKUS, EU and UK shareExports to RussiaImports from RussiaExports to IranImports from Iran
India, 2025 own report445.892.673.713.840%4.562.91.20.9

UN Comtrade query, India 2025

Goods only; services are not included. Values as India reported them to UN Comtrade, read 6 October 2026.

Outlook

What to watch

Dated decisions ahead, and recent official statements, court rulings and company actions, each with its source.

  1. Graham Act deadline. Section 113 requires the President to raise the duty on all goods from countries that were among the five largest importers of Russian crude or gas in the 12 months before 18 September 2026, and that knowingly buy again from 18 October, to up to 100%, unless he waives it. In CREA’s data India was the second-largest importer of Russian crude in that period.

    Public Law 119-111 · The Graham Act page

  2. Section 103 of the same Act gives the President 30 days from enactment (to 18 October 2026) to impose all the sanctions it lists on Sberbank, VTB Bank, Gazprombank and other Russian state-owned banks. The same applies to any foreign financial institution that engages in significant transactions with them, unless the Treasury Secretary determines that sanctioning that institution is not consistent with US economic or foreign-policy interests. From the same date, US persons must be barred from transacting with all of these institutions. The President must review the list by 16 April 2027 (210 days after enactment) and every 180 days after that.

    Public Law 119-111

  3. The UK’s temporary licence that still allows imports of diesel and jet fuel refined from Russian crude in third countries will expire by 1 January 2027. The UK ban on such refined products took effect on 20 May 2026, and the licence is reviewed every two weeks.

    UK government, 12 June 2026

  4. The Ministry of External Affairs said the Foreign Secretary had raised India’s concerns about the Act and its implications for bilateral relations with a visiting US Congressional delegation, led by House Foreign Affairs Committee chair Brian Mast, on 27 September.

    MEA briefing, 29 September 2026

  5. In Nayara Energy Ltd v SAP India Pvt Ltd (CS(COMM) 1006/2025), the Delhi High Court ordered SAP India to restore the software support it withdrew from Nayara on 24 July 2025. SAP had withdrawn it citing EU Implementing Regulation 2025/1476 of 18 July 2025, which listed Nayara. At this interim stage, the court held that EU sanctions could not be relied on to avoid obligations under contracts governed by Indian law. The findings are prima facie.

    Delhi High Court, judgment of 21 September 2026

  6. Bloomberg, citing unnamed people involved in the talks, reported that India’s main refiners had begun looking for alternatives to Russian crude cargoes for November delivery after the Graham Act became law. The report cited Kpler estimates that imports from Russia might average about 1.9 million barrels a day in September, the lowest since April.

    Business Standard (Bloomberg), 21 September 2026

  7. The MEA said the Government had noted the passage of the Sanctioning Russia and Iran Act in the US Congress and was monitoring developments. It said India would continue to ensure energy security for its 1.4 billion people through diversified sourcing, and that the Government would work with Indian trade and industry bodies on the implications.

    MEA statement, 17 September 2026

  8. OFAC added an Iran listing to Russia’s VTB Bank, whose US list entry names a New Delhi branch, and Treasury warned that foreign banks dealing with it may face secondary sanctions.

    Treasury press release sb0629 · OFAC Recent Actions, 14 September 2026

  9. CREA estimated that India was the second-largest buyer of Russian fossil fuels in August 2026, importing EUR 4.8 bn, of which EUR 4.1 bn was crude oil. Over the whole period from 5 December 2022 to the end of August 2026, CREA estimated that China bought 50% of Russia’s crude exports and India 37%.

    CREA, August 2026 monthly analysis

  10. Council Regulation (EU) 2026/1848 of 23 July 2026 added ‘Sberbank India’ and ‘India VTB’ to Part A of Annex XLV to Regulation 833/2014, with effect from 13 August 2026. Part A lists credit and financial institutions established outside the EU with which EU operators may not transact.

    Council Regulation (EU) 2026/1848

  11. At the 17 July 2026 briefing, the MEA spokesperson said the US sanctions waiver covering India’s Chabahar port project in Iran had ended some time earlier. He said India was in discussion with relevant stakeholders on how to take the matter forward.

    MEA briefing, 17 July 2026

  12. Two days after the US listed Rosneft and Lukoil on 22 October 2025, Reliance Industries said it would comply with US and other Western sanctions on Russian oil and adjust its refinery operations to meet them. It also said it would follow EU rules on importing refined products into Europe.

    ThePrint (PTI), 24 October 2025

  13. Adani Group barred tankers sanctioned by Western governments from entering its ports, according to Reuters as cited by Business Standard. The same report said an EU- and UK-listed tanker carrying Russian crude for HPCL-Mittal Energy then diverted from Mundra to Vadinar.

    Business Standard, 17 September 2025

  14. State Bank of India stopped processing trade and foreign-currency transactions for Nayara Energy, which the EU listed on 18 July 2025, according to an Economic Times report cited by Business Standard. The report quoted a person familiar with the matter as saying there had been no government direction.

    Business Standard, 12 August 2025

  15. Answering media queries on the EU sanctions package announced that day, which listed Nayara Energy, the MEA said India had noted the sanctions and does not subscribe to unilateral sanction measures. It said India remains committed to its legal obligations and called for no double standards on energy trade.

    MEA response, 18 July 2025

  16. Asked about US sanctions on 19 Indian companies and two Indian nationals over dual-use supplies to Russia, the MEA spokesperson said India understood that the sanctioned transactions and companies were not in violation of Indian laws. He said the government was working to inform Indian companies about the export-control rules that apply to them.

    MEA briefing, 2 November 2024

Method

Data, method and sources

Download the data

How the monitor works

  • Every record is a US, EU or UK measure as the authority published it, linked to the official page or act.
  • Window: measures dated 1 January 2024 or later, to the list dates on the method page.
  • Programme (Russia or Iran) is the authority’s own tag or regime; measures under other programmes are left out.
  • Hong Kong is shown apart from mainland China, from the address the authority gives.
  • Every record was checked a second time against an official source; corrections are made within two working days and logged.

The full method, sources and corrections log

How to cite. The Geopolitical Economist (2026). Third-Country Sanctions Monitor. Version 1, updated 7 October 2026. https://geopoliticaleconomist.com/research/trackers/third-country-sanctions

Change log

  1. Published as version one: four countries, US, EU and UK measures since January 2024.

Not legal advice. A listing records an official action by the authority named; it is not a finding by this publication. Check the official list before acting. Corrections: write to [email protected] with the record ID and your source; corrections are made within two working days and logged on the method page.