Credit: Svtk44 via Wikimedia – Oil refinery plant Yaroslavnefteorgsintez in Yaroslavl town, Russia (2021)
Last month, the EU released its largest-ever sanctions package, targeting almost [1600 entities](https://www.consilium.europa.eu/en/press/press-releases/2026/10/12/russia-s-war-of-aggression-against-ukraine-eu-agrees-largest-ever-package-of-listings-targeting-almost-1600-individuals-and-entities-in-russia-s-military-industrial-complex/) at the core of Russia’s military-industrial complex. Since Russia’s full-scale invasion of Ukraine in 2022, the increasingly complex geopolitical landscape has seen sanctions evolve to tackle an [ever-wider range of threats](https://www.hsfkramer.com/notes/fsrandcorpcrime/2026-posts/ofsi-strategy-2026-29-key-takeaways), shifting from targeting oligarchs, companies and banks, to supply chains, crypto wallets, and even [physical infrastructure](https://finance.ec.europa.eu/document/download/85a81676-9f77-4d35-9c48-003e5535763b_en?filename=faqs-sanctions-russia-infrastructure-transaction-ban_en.pdf) such as ports and oil refineries. Recent EU sanctions packages have focused on crippling the war machine from all angles and homing in on the loopholes Russia has created to circumvent them: rerouting trade through third countries, building a shadow fleet to move oil around the price cap, and using alternative payment channels like crypto networks. ## How sanctions are changing The EU has issued over [20 sanctions packages](https://www.consilium.europa.eu/en/policies/sanctions-against-russia/timeline-packages-sanctions-since-february-2022/) since February 2022, which the UK and allies have often moved in parallel with. Over time, these have broadened in scope, shifting from earlier finance-focused packages to increasingly targeting supply chains, the shadow fleet, and technology sectors: - [October 2026](https://www.consilium.europa.eu/en/press/press-releases/2026/10/12/russia-s-war-of-aggression-against-ukraine-eu-agrees-largest-ever-package-of-listings-targeting-almost-1600-individuals-and-entities-in-russia-s-military-industrial-complex/): The EU Council adopted additional restrictive measures targeting 1,569 entities in Russia’s military-industrial complex. The listed companies supply key components to some of Russia’s most advanced weapons systems, including missiles, UAVs, and aircraft. - [July 2026](https://www.consilium.europa.eu/en/press/press-releases/2026/07/23/21st-package-of-sanctions-eu-hits-russian-energy-financial-services-and-crypto-hard/): The EU’s 21st sanctions package, released earlier this year, targeted over a hundred banks and crypto operators, 40+ vessels in Russia’s shadow fleet, and several oil refineries in Russia and Belarus. It included designations related to the cross-border [A7 Network](https://www.opensanctions.org/entities/NK-LWe624wpJaurf8FVBEQJk2/), including its new links to Africa, and also extended its transaction ban to 14 crypto-related service platforms based in Georgia, Panama, the UAE, the Marshall Islands, Kyrgyzstan, and Belarus. - [April 2026](https://www.consilium.europa.eu/en/press/press-releases/2026/04/23/russia-s-war-of-aggression-against-ukraine-20th-round-of-stern-eu-sanctions-hits-energy-military-industrial-complex-trade-and-financial-services-including-crypto/): The 20th package introduced new restrictions on energy, finance, maritime, and technology sectors, plus stronger anti-circumvention measures against third-country entities. The package banned transactions with two Russian ports – [Murmansk](https://www.opensanctions.org/entities/eu-oj-4ab9fa371f2651c018fd31c4ade695696206bce5/) and [Tuapse](https://www.opensanctions.org/entities/eu-oj-54e923bcf60b5330420ffec70bd4a8cdd0a5bf90/) – and with the oil terminal at the port of [Karimun](https://www.opensanctions.org/entities/eu-oj-c7abf2a11f4d7d6f37a9c2526b8e1630a75de5a9/) in Indonesia, which are used to circumvent the oil price cap.Sanctions come in all shapes and forms
## A data model that adapts Sanctions programs keep identifying new categories of targets, and a data model only stays useful if it's built to be extended and adapted as regulation evolves. OpenSanctions is based on the [FollowTheMoney](https://followthemoney.tech/) (FtM) data model, which defines entities like people, companies, and assets, and maps the relationships between them. Because sanctions authorities now list vessels, aircraft, and crypto wallets directly, FtM treats each as a matchable entity type in its own right. A [Vessel ](https://www.opensanctions.org/reference/#schema.Vessel) carries an IMO number that stays with the hull through renames, sales, and reflagging, along with past flags and previous names, so its history leaves a trail. Similarly, an [Airplane](https://www.opensanctions.org/reference/#schema.Airplane) carries a serial number, registration number, model, and build date. Because each can be matched on its own identifiers, a tanker or aircraft can be screened as a target regardless of who owns it today. The FtM model started as an analytical tool for cross-border investigative projects. Since then, the model has evolved in direct response to how sanctions themselves have changed. It also underpins the wider Aleph ecosystem, including the [OpenAleph](https://openaleph.org/) platform, which allows you to search, connect, and cross-reference information across datasets (see this recent vessel investigation [walk-through](https://openaleph.org/blog/2026/exploring-openaleph-a-practical-guide-to-investigations/) from our friends at DARC, who manage the platform).Starlit one of many Russian tankers with a habit of “going dark”
## A connected graph FtM ensures entities from different sources speak the same language and sit in one connected graph, so you can trace ties from a sanctioned entity outwards. This structure really pays off when investigating networks like the shadow fleet; for example, it highlights separate companies that hold different roles linked to a sanctioned tanker – such as the owner, operator, technical manager and classification society – and where possible, identifies ownership and control, percentages held, and start and end dates. A screening hit on a vessel can therefore be traced to the corporate network around it.The web of entities of interest surrounding Starlit
The data model is designed to be adaptable and agile, evolving alongside regulations. New target types are defined as [schemata](https://followthemoney.tech/explorer/schemata/) that inherit common properties from parent types (a Vessel is a kind of [Asset](https://followthemoney.tech/explorer/schemata/Asset/), and therefore a kind of [Thing](https://followthemoney.tech/explorer/schemata/Thing/)), so adding one doesn’t mean redesigning the model. ## The case for open data Governments publish sanctions lists as public information, yet many data vendors provide that data in a proprietary format. We’ve taken a slightly different approach: keeping our tech stack open-source is a quality-assurance measure that means every compliance decision is traceable to the data that triggered it. Our open methodology also exposes our dataset to broad scrutiny, whether from a compliance lead, a journalist, a regulator, or even the persons and entities that have been designated. Our methodology grows and matures with every regulatory development or piece of feedback, and, in an open infrastructure, that knowledge compounds in one place, for everyone’s benefit.