Secondary sanctions in 2026: how companies protect imports and exports from indirect restrictions

Modern Western restrictions work on the principle of dominoes: any market participant can suffer, even if it is not directly related to sanctioned countries or individuals. Secondary sanctions hit through counterparties – banks, logisticians, and suppliers. It takes one link in the chain associated with a “toxic” subject for the transfers to “freeze,” the cargo is arrested, and key partners curtail cooperation.

According to recent polls by the Institute for Economic Forecasting (INP) of the Russian Academy of Sciences in November-December 2025, the share of companies that felt the negative impact of sanctions increased to 71.2%. At the same time, the proportion of enterprises not affected by restrictions decreased to 24.3%, while a year earlier their share was 31.5%. Half of the respondents rated the consequences of sanctions as unambiguously negative. Sanctions have ceased to be an “event” and have become a constant backdrop for doing business – a new baseline of increased risks and costs.

Mechanism of secondary sanctions

Secondary sanctions are not an abstract threat, but a clear legal tool that triggers a cascading effect. The bottom line is that regulators get the right to punish any company in the world if its operations, according to them, significantly help the primary sub-sanction facility. In 2025, the practice of secondary sanctions continued to expand, and in May 2026, the United States announced a new stage: now secondary sanctions can be applied to foreign banks for operations with any sanctioned Russian persons and organizations, and not only with the defense sector.

A real example from 2025-2026: the contract is signed, the payment is sent, the goods are almost on the way. Suddenly the correspondent bank freezes the transfer “for verification,” the insurer withdraws coverage, and the shipping line revises the conditions for entering the port. No one has officially imposed sanctions against you, but business processes are consistently stopped. This is the insidiousness of the mechanism: legally you are clean, in fact – isolated. The blow is inflicted not on a geographical basis, but on the meaning: if the operation at least indirectly “supports” the regime objectionable to the initiators of the sanctions, the business falls out of the game.

The three main risk channels are:

Financial transactions. The intermediary bank checks not only your direct partner, but also the entire chain of beneficiaries. Banks in the UAE, Turkey and China in 2024-2025 massively tightened compliance, blocking accounts and stopping payments of Russian companies at the slightest suspicion of communication with sanctionned structures. If a connection with the sanctions list is found, the bank is obliged to block or return the payment – to protect itself.
Logistics and insurance. The shipping line or the insurer, having found out that the cargo goes to the port involved in the transit of sanctioned goods, may refuse to service. In May 2025, the European Union approved the 17th package of sanctions with a focus on shipping, logistics and cross-border settlements. About 340 vessels of the so-called “shadow fleet” used to transport Russian cargo bypassing sanctions were under restrictions.
Supply chain. An externally safe supplier can use critical components from a subcontractor whose operations are partially financed through a sub-sanction structure.

In fact, secondary sanctions turn all market participants into each other’s controllers, forcing them to check each step against a growing list of requirements. The task of business is not just to avoid direct forbidden connections, but to learn to recognize these hidden relationships.

The most vulnerable places in the supply chain

Practice of 2025-2026 shows: most often “torn” units are not factories and warehouses, but nodes of financial and logistics infrastructure.

Financial circuit: payments through third countries, correspondent banks, currency conversion. Even a correctly executed transfer can freeze due to the “reputation filter” – banks, fearing blocking their own operations, hypertrophically check transactions related even indirectly to limited countries or individuals. Even Turkish banks that served payments for Russian gas (its supplies to Europe in January-April 2025 increased by 9.5%) began to check strictly transactions due to the threat of secondary sanctions, which slowed down some operations.
Insurance and reinsurance. Often it is the insurance market that is the first to refuse risk, and without a policy, the cargo is not taken into work. Global reinsurers fear secondary sanctions and do not cover deliveries to certain jurisdictions or with certain counterparties.
Freight forwarders and carriers. Large international logistics operators are forced to comply with US and EU requirements due to their assets around the world. Even if the route does not cross them, the threat of blocking dollar settlements makes us refuse “suspicious” contracts.
Origin of article and components. If in the final product the share of components from the sanctioned country exceeds the threshold (often 25% or lower), all goods can be considered originating from there. It is very difficult to confirm a “clean” origin without in-depth analysis of the entire supply chain.
Last mile – terminals, ports, warehouses. Operators of transport hubs introduce manual checks of documents and the origin of goods, fearing for reputation. Containers with formally correct papers can stand idle for weeks awaiting approval.

Logistics route changes in 2025-2026

Under the pressure of sanctions, traditional transit hubs – Kazakhstan and Kyrgyzstan – faced tough checks from the United States and the EU. Banks of these countries massively refuse operations with Russian counterparties, and customs carefully checks goods with a double purpose. In response, logistics companies reoriented to less visible routes:

through Uzbekistan and Tajikistan, where control is still weaker;
through Vietnam, Malaysia and Indonesia as key transshipment points for goods going to Russia;
through Singapore, where there are still no strict restrictions on trade with Russian companies;
through African countries – Senegal and Ghana, where the final recipient is rarely checked.

Additionally, Russia has stepped up the use of the Northern Sea Route for the supply of raw materials and goods to the markets of China, India and other Asia-Pacific countries, reducing the route between Europe and East Asia by about a third compared to the route through the Suez Canal.

Proactive protection: not a formality, but an ongoing process

The main mistake is to treat sanctions compliance as the responsibility of lawyers, because in fact it is an operational tool.

What can help:

Deep verification of counterparties. Not only the name should be studied, but also the ownership structure, beneficiaries, logistics, banks, transaction history. KYC protocols in 2025 came to the fore: foreign banks check not only your direct partner, but also his key counterparties, and your reputation now equals the reputation of your “weakest” partner.
Sanctions clauses in contracts: the right to stop a deal without fines, change the route, carrier or currency.
Separate logistic circuits. Practice confirms: companies that have developed flows of “clean” and “high risk” experience crises more easily.
Internal stop lists and scripts. Strong players are prescribed in advance what to do when blocking a payment: an alternative route, a reserve settlement channel, an insurer.

Diversification as a survival strategy

Previously, diversification was needed to save money and choose the best conditions. Today it is a tool for sustainability in a chaotic global market.

Companies that depend on one supplier, one country and one route are constantly in the turbulence zone. Those who have created alternative chains in advance through Asia, the Middle East, Africa or localization within the country benefit from stability. They can quickly switch flows and negotiate from a position of strength.

Diversification is more complicated than just “finding a second supplier.” This is a restructuring of the entire architecture: routes, payments, insurance, warehouse logic. It takes time and investment. Key principles: double supply for critical components, redundancy of financial infrastructure (banks of different jurisdictions, different payment protocols), distribution of stocks in several regional warehouses. As a result, the linear supply chain turns into a flexible fault-tolerant network.

What to do if secondary sanctions affect you

The first mistake is panic and stopping operations. The second is an attempt to break through the old channels.

Correct algorithm of actions:

Legal analysis of the foundation. Not every blocking is sanctions. Often, it is simply the over-caution of a particular mediator.
Communication with regulators and banks. Sometimes a well-written package of documents removes the lock faster than replacing the entire scheme.
Emergency restructuring of routes – reserve carriers, alternative ports, other payment channels. All this must be ready in advance.

It is also important to communicate honestly with customers. Hiding problems is the worst strategy.

What businesses need to remember

Secondary sanctions are not a legal, but an operational task. They require a holistic view of the entire value chain: from the purchase of raw materials to delivery to the client. Each stage should be analyzed for sanctions risks.

Companies that consider logistics and foreign economic activity as a strategic function, invest in compliance services, systems for tracking the origin of goods and build network (rather than linear) logistics – win. The rest continue to wonder why the formally permitted cargo suddenly stopped going.

Today, the winner is not the one with the lower rate, but the one with the more reliable system. Success is measured not only by margins, but also by the ability to ensure business continuity in the face of disruption. Such a system stands on three pillars: deep diversification of channels, technological transparency of all operations and proactive risk management. In the new reality, the cost of operational sustainability is becoming the main competitive advantage.