The UK government’s sanctions enforcement record reveals a troubling pattern: high-profile announcements targeting thousands of individuals and entities whilst actual enforcement remains largely symbolic. When the Office of Financial Sanctions Implementation launched over 100 investigations into law firms since 2021 yet publicly punished just one, the question of whether Russian sanctions function as genuine foreign policy or political theatre becomes unavoidable. Meanwhile, Russia’s shadow fleet has expanded to carry approximately 70% of seaborne oil exports, demonstrating how evasion networks operate with relative impunity whilst innocent individuals bear disproportionate punishment.
The Herbert Smith Freehills case illustrates enforcement priorities that favour symbolic gestures over systematic accountability. The law firm’s Moscow subsidiary received a £465,000 penalty for six payments totalling £3,932,392 to sanctioned Russian banks – Alfa-Bank JSC, PJSC Sovcombank, and PJSC Sberbank – during a seven-day wind-down period following Russia’s invasion. These payments occurred as the firm closed its Russian offices, demonstrating what OFSI characterised as “a pattern of failings.”
Yet this single public enforcement action from over 100 law firm investigations raises fundamental questions about regulatory capacity and strategic priorities. If major international law firms with sophisticated compliance infrastructure breach sanctions during routine operations, how can smaller businesses without comparable resources possibly navigate the regime successfully? This complexity advantage benefits well-resourced professional facilitators whilst crushing those lacking advanced regulatory capabilities.
The Shadow Fleet Problem
Whilst enforcement focuses on law firm accounting errors, a massive sanctions evasion infrastructure operates with far greater impunity. The Kyiv School of Economics estimates that approximately 70% of Russia’s seaborne oil exports now travel on vessels specifically assembled to circumvent restrictions. These tankers operate through elaborate corporate structures designed to obscure beneficial ownership and evade designation.
The UK’s response exemplifies the symbolic approach that characterises current policy. In May 2025, authorities sanctioned John Ormerod, a 74-year-old British ship finance veteran, for allegedly purchasing at least 25 secondhand tankers for Russia’s shadow fleet between December 2022 and August 2023. Financial Times reporting revealed how Russian oil producer Lukoil financed Ormerod through its shipping division, with transactions totalling over $700 million.
Each tanker was acquired by a special-purpose company Ormerod established in the Marshall Islands, whilst Lukoil’s Dubai-based Eiger Shipping provided funding through advance charter payments. Ormerod’s lawyers noted he ended his association with the tankers before they were sanctioned, and that shipbroker Braemar facilitated at least nine transactions. This case demonstrates the sophisticated networks enabling sanctions evasion – yet enforcement actions remain sporadic and reactive rather than systematic and preventive.
The question of why sanctions on Russia fail to prevent such large-scale evasion reveals fundamental structural problems. Professional facilitators create corporate architectures specifically designed to exploit jurisdictional gaps and regulatory complexity. Marshall Islands registration, Dubai financing, and multiple intermediary transactions create opacity that overwhelms enforcement capacity. When a single individual can facilitate $700 million in shadow fleet purchases before being sanctioned, the regime clearly prioritises symbolic designation over preventing evasion.
Enforcement Resource Gaps
The disparity between designation volume and enforcement capacity creates a sanctions regime that appears comprehensive on paper whilst remaining ineffective in practice. The UK has designated over 2,000 Russian individuals and entities, yet lacks resources to effectively monitor compliance or pursue violators systematically. This creates a system optimised for political signalling rather than strategic impact.
Former British diplomat Ian Proud, who authorised approximately half of UK sanctions against Russia, testified that internal Foreign Office assessments concluded individual and entity sanctions have “practically no impact within six months of their imposition.” His evidence that 92% of travel restriction sanctions targeted Russians who had never visited the UK and never intended to visit underscores how designation serves political rather than strategic purposes.
When are Russian sanctions working becomes measured by volume of designations rather than behavioural outcomes, the entire architecture reveals itself as performance rather than policy. The impact of sanctions on Russia includes accelerated development of evasion infrastructure whilst enforcement actions target low-hanging fruit like law firm administrative errors rather than systematic facilitators.
The Complexity Advantage
The Herbert Smith Freehills case crystalises a fundamental injustice in current sanctions architecture. A major international law firm with dedicated compliance teams, legal expertise, and substantial resources committed breaches during a brief wind-down period under extraordinary circumstances. If such organisations cannot maintain perfect compliance, what realistic expectation exists for smaller businesses?
This creates a two-tier system where well-resourced actors can afford sophisticated compliance infrastructure and specialised legal advice whilst smaller entities face impossible navigation challenges. The result rewards scale and resources rather than good faith compliance efforts. Meanwhile, professional sanctions evaders exploit this complexity deliberately, creating corporate structures so opaque that enforcement becomes practically impossible.
The Office of Financial Sanctions Implementation’s investigation of “dozens of law firms” yielding one public penalty suggests either remarkable compliance across the legal sector or enforcement incapacity. Neither interpretation supports confidence in the regime’s effectiveness. If compliance is universal among sophisticated actors, why do shadow fleet operations proliferate? If enforcement capacity is inadequate, why expand designation lists that cannot be effectively monitored?
Strategic Reassessment Needed
Three years into unprecedented Western sanctions, sanctions are not working to achieve their fundamental statutory purpose of encouraging Russia to cease actions destabilising Ukraine. Instead, they’ve created a regime where innocent individuals face devastating punishment for historical associations whilst professional facilitators operate vast evasion networks with manageable risk.
The UK’s symbolic enforcement approach – one law firm penalty from over 100 investigations whilst shadow fleets expand by 70% – demonstrates how current policy prioritises political theatre over strategic effectiveness. Until enforcement capacity matches designation ambition and resources target systematic evasion rather than administrative errors, sanctions will continue generating injustice without meaningful contribution to foreign policy objectives. The evidence demands acknowledgment that EU sanctions Russia policies and their UK equivalents have failed to prevent adaptation, failed to change Russian behaviour, and failed to justify their substantial human and economic costs.
