"[These countries] know that sanctioning countries are willing to accept this. This is a loophole. It's entirely legal.

Everyone's aware of it, but nobody is doing much to actually tackle it in a big way," says Vaibhav Raghunandan, an analyst at CREA. Campaigners and experts argue that Western governments have the tools and means available to stem the flow of oil and gas revenue into the Kremlin's coffers. According to former Russian deputy energy minister Vladimir Milov, who is now a diehard opponent of Vladimir Putin, sanctions imposed on trade in Russian hydrocarbons should be better enforced – particularly the oil price cap adopted by the G7 group of nations, which Mr Milov says "is not working, external".

He is fearful, though, that the US government shake-up launched by President Donald Trump will hamper agencies such as the US Treasury or the Office of Foreign Assets Control (OFAC), which are key for sanctions enforcement. Another avenue is continued pressure on Russia's "shadow fleet" of tankers involved in dodging the sanctions. "That is a complex surgery operation.

You need to periodically release batches of new sanctioned vessels, shell companies, traders, insurers etc. every several weeks," Mr Milov says. According to him, this is an area where Western governments have been much more effective, particularly with the introduction of new sanctions by Joe Biden's outgoing administration in January 2025.

Mai says that banning Russian LNG exports to Europe and closing the refining loophole in Western jurisdictions would be "important steps in finishing the decoupling of the West from Russian hydrocarbons". According to Mr Raghunandan from CREA, it would be relatively easy for the EU to give up Russian LNG imports. "Fifty percent of their LNG exports are directed towards the European Union, and only 5% of the EU's total [LNG] gas consumption in 2024 was from Russia.

So if the EU decides to completely cut off Russian gas, it's going to hurt Russia way more then it's going to hurt consumers in the European Union," he told the BBC.