On Fourth Anniversary of Putin's Full-Scale War, New Banking Committee Analysis Highlights Range of Targets Left Unsanctioned by Trump Administration

President Trump promised to end the war within 24 hours as President. Instead, he ended regular Russia sanctions designations, leaving hundreds of evaders free to continue undermining U.S. and Ukrainian leverage while Putin continues his brutal war

U.S. sanctions rollouts under the Russia program fell from at least 32 each year to a single rollout over the entire fourth year of the war, while our allies designated hundreds of targets

Washington, DC - Minority Staff for the Senate Committee on Banking, Housing, and Urban Affairs released a new analysis highlighting a range of targets the Trump Administration has left unsanctioned, allowing hundreds of evaders to benefit Russia's war machine while undermining U.S. and Ukrainian negotiating positions to achieve a just peace. On the fourth anniversary of Putin's full-scale war on Ukraine, G7 partners including the United Kingdom and European Union are once again implementing and preparing packages of targeted sanctions. But President Trump continues failing to use his broad authority to act against anyone supporting Russia's war machine.

During the first three years of Russia's full-scale war, the Departments of the Treasury and State implemented no fewer than 32 sanctions rollouts annually, with each rollout consisting of sometimes hundreds of designations of those around the world who had facilitated Russia's aggression. This helped undermine Russia's war effort, making it harder for the war machine to procure critical items and raise revenue. It also demonstrated to the Kremlin that the costs of continued aggression would only grow over time.

In comparison, over the entire fourth year of Russia's war-when the United States could have helped demonstrate that Russia cannot erode or wait out our pressure-the Trump Administration implemented one sanctions rollout in response to the war. This reflects a choice to end what had been regular U.S. actions to identify, expose, and disrupt new Russian circumvention methods, with the Administration forgoing what would likely have been more than one thousand designations. Meanwhile, the European Union designated nearly 900 additional parties under its Russia program in 2025.

When asked at a hearing why the U.S. Treasury had halted regular counter-evasion sanctions, Treasury Secretary Bessent responded that the Administration's lone rollout targeting two Russian oil majors-Rosneft and Lukoil-had been sufficient. The Trump Administration delayed sanctioning those oil companies for eight months, even as market conditions provided an opportunity to follow up on the previous Administration's designations of two other oil majors. After the Trump Administration sanctioned Rosneft and Lukoil in October 2025, its lack of effort to address circumvention has left those designations easily evaded by Russia.

President Trump stated at least 53 times that he would end Russia's war on Ukraine within 24 hours of being sworn in. Instead, the Trump Administration's failure to implement effective sanctions and export controls for the past year has coincided with heightened suffering for the Ukrainian people since President Trump returned to the White House. According to one overview, Russia killed 20 percent more Ukrainian civilians in 2025 compared to 2024; Russia sent almost five times as many long-range drones to hit civilian targets compared to 2024; Russia fired three times as many ballistic missiles at Ukraine compared to 2024; and "Moscow has practically destroyed Ukraine's power grid during the country's harshest winter in more than a decade."

Russia remains "enormously dependent on imports" for "key technologies and industries for the war." That reliance on imports and financial facilitation creates an opportunity for impactful sanctions designations. So it is unclear why any President serious about negotiating the best peace possible would instead let our sanctions leverage wither. Without follow-up actions, evaders are brazenly profiting without any U.S. pushback, and the Kremlin knows it. That only improves Russia's negotiating position.

Below, Committee staff highlight a range of potential targets, based on open source information alone, that the Trump Administration could have considered sanctioning over the past year of U.S. inaction-and could start addressing as soon as today if it were serious about achieving a just peace.

Those reportedly facilitating Russia's procurement of critical goods and technology, such as:

• More than 130 companies identified in mainland China and Hong Kong as "advertising immediate sales of restricted computer chips to Russia," including several that "have sent restricted components to Russia in violation of U.S. export controls, trade data, online listings and corporate registration records show."

• Individuals and entities involved in the massive summer 2025 increase in Chinese exports to Russia of fiber-optic cables and lithium-ion batteries needed for specialized drones that have enabled Moscow to strike Ukrainian defenses, according to trade data, shipping records, and company statements.

• Entities supplying the Chinese parts in photos Secretary Bessent said he had in October 2025 indicating that these parts comprise "substantial amounts" of Russia's drones.

• Numerous other Chinese companies that, according to the Trump Administration itself, provide roughly 80 percent of Russia's dual-use imports.

• Entities in third countries other than China that supply Russia's drone-production pipeline with sensitive American and European technology.

• Individuals and entities in third countries like Thailand that are helping transship Chinese drones to Russia. Russia reportedly imported eight times as many drones from Thailand in 2025 as it did in 2024.

• Producers and suppliers across Central Asia, the Middle East, South Asia, and Southeast Asia targeted by our partners for helping Russia's military obtain machine tools, electronics, and other dual-use goods, including microprocessors used in weapons systems.

• An Indian company that reportedly "shipped $1.4 million worth of an explosive compound with military uses" to Russia, despite prior U.S. warnings about the specific explosive compound.

• Other companies and individuals the United Kingdom targeted for supplying chemicals and explosives to Russia to manufacture missiles and other weapons systems.

• Logistics networks reportedly helping Russia import motor oil additives, lubricants, and other chemicals with military applications from G7 jurisdictions.

• Individuals who reportedly set up corporate entities in third countries to facilitate shipments of high-priority items to Russia from G7 countries.

Payment mechanismsreportedly used for sanctions evasion, such as:

• The numerous undesignated global affiliates and enablers of A7, a mechanism reportedly now moving tens of billions per month around our sanctions and claiming to account for nearly 19 percent of the total volume of foreign trade operations of Russian businesses. Despite one U.S. cyber sanctions rollout in August 2025 that has clearly proved to be insufficient, "A7 stands out not only for its scale, but for its role as centrally coordinated sanctions evasion architecture tied to Russian state interests."

• Chinese financial institutions likely involved in facilitating the large volume of dual-use exports or reexports to Russia. The European Union targeted two Chinese banks for facilitating sanctions evasion last year.

• Other third-country financial institutions likely facilitating Russia sanctions evasion. The European Union targeted several banks in Central Asia last year.

• Third-country banks connecting to the Financial Messaging System of the Central Bank of Russia (SPFS) system. The European Union acted against banks last year for their use of SPFS.

• Individuals and entities related to "The China Track," a netting payments system that major Russian banks were reportedly setting up for transactions with the PRC to work around U.S. sanctions, featuring "a web of intermediaries registered in countries that Russia considers friendly."

Those reportedly generating revenuefor the Kremlin's war machine, such as:

• Individuals and entities helping Russia start up a multibillion-dollar energy revenue stream by facilitating the first ever deliveries from its flagship Arctic LNG 2 project, previously chilled by regular U.S. sanctions designations. Almost six months ago, headlines warned that "China is Cranking Up Its LNG Trade With Russia in Test For Trump" and market analysts warned that "Any OFAC action (or lack of it) will determine whether Arctic LNG 2 volumes continue to find new markets in other countries." As Senators have repeatedly raised, the Trump Administration has done nothing in response.

• Individuals and entities that have been smuggling at least $90 billion in Russian oil around U.S. restrictions, including around the Administration's designation of Rosneft. This reportedly includes Redwood Global Supply and numerous other entities in the UAE, India, and other countries, as well as individuals like the Azeri nationals reportedly behind several of these companies.

• Additional Russian oil companies such as Tatneft that the United Kingdom has sanctioned.

• Vessels with opaque ownership-known as shadow fleet or dark fleet vessels-that Russia has used to export oil or petroleum products. The European Union and United Kingdom have blocked hundreds of these vessels without the United States over the past year, even though matching U.S. sanctions would have amplified the impact.

• Individuals and entities in the shadow fleet value chain that the European Union has targeted, like companies managing shadow fleet vessels, traders of Russian oil, the captain of a shadow fleet vessel, and an operator of an open flag registry. The United Kingdom has also targeted a foreign national who procured shadow fleet vessels for Russia.

• Russian state-owned vessels used to export Russian oil and increasingly to export LNG-and any individuals or entities helping Russia acquire these vessels-as Russia attempts to expand its fleet of specialized ice-class natural gas tankers.

• Vessels that have reportedly engaged in ship-to-ship transfers with sanctioned vessels so that the "clean" vessels can deliver shipments from Russia's Far East ports.

• Entities or foreign individuals involved in a natural gas deal reportedly signed in fall 2025 between a major Russian energy company and an American investor, even as Russia continues to kill Ukrainian civilians and to pose major illicit finance risks regardless of sanctions. (The American investor served as a finance vice chairman for President Trump's 2017 inauguration.)

• The Administration could have joined the United Kingdom and the European Union in lowering the price cap for seaborne Russian oil last year, or in considering a full maritime services ban for shipments of Russian oil.

• The Administration could have joined or recognized the European Union's ban on imports of refined oil products derived from Russian crude. India's largest fuel refiner said in November that the EU ban drove its reduction in crude imports from Russia.

Those reportedly responsible for human rights abuses, such as:

• Individuals and entities responsible for forced deportation or indoctrination of Ukrainian children, which only foreign partners have continued designating after the Trump Administration ended regular U.S. sanctions rollouts.

• Officials and other individuals responsible for Russia's reported trafficking of foreign recruits from Africa and Asia to fight in the Kremlin's war of choice.

• Russian individuals such as soldiers and prison guards who are reportedly responsible for sexual violence against hundreds of Ukrainian women and girls.

• Russian intelligence agents such as those the United Kingdom sanctioned for plotting an attack on Ukrainian supermarkets and a unit the United Kingdom sanctioned for helping target missile strikes against Mariupol, including Russia's strike on the Mariupol Theater that killed hundreds of civilians.

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