The UK National Crime Agency (NCA), Office of Financial Sanctions Implementation (OFSI), and Foreign Commonwealth & Development Office (FCDO) issued this red alert to provide information to assist financial institutions in identifying potential sanctions evasion in relation to the sale of Russian oil and gas. 

• View the full Red Alert issued in July 2025

Red flags to watch out for

The notice contains explanations on the schemes used and a list of red flags. It states that:  

“No single red flag is necessarily indicative of illicit or suspicious activity, all the surrounding facts and circumstances should be considered before determining whether a specific transaction or customer is suspicious or associated with potential sanctions evasion.” 

The following red flags are listed: 

• Companies with limited trading history very quickly trading large volumes of oil.

• Limited information on ownership, directors or beneficiaries.

• Multiple transfers between obscure companies.

• Companies registered or operating in known jurisdictions of high risk, including those where shadow fleet entities are known to operate.

• The companies often have a limited online presence with no company website or contact information. If a website does exist, generally it will contain generic stock photos, and no details on the individuals operating the company.

Anti-Money Laundering (AML) resources

Solicitors should note that while the Law Society is not the competent authority for sanctions in Ireland, the AML section of the website contains relevant information on sanctions and links to the Central Bank, Department of Foreign Affairs and Department of Jobs, Enterprise and Innovation websites. You can also access other services like our AML helpline for solicitors.

• Sanctions and high-risk jurisdictions lists