COREDO – EU Legal & Compliance Services Expert legal consulting, financial licensing (EMI, PSP, CASP under MiCA), and AML/CFT compliance across the European Union. Headquartered in Prague, we provide seamless regulatory solutions in Germany, Poland, Lithuania, and all 27 EU member states.
Alena Mach
17.08.2025 | 6 min read
Updated: 24.10.2026
The global metallurgical business under sanctions is going through tectonic shifts: metal exports face direct and indirect restrictions, and the EU and NSDC sanctions lists keep expanding. As a result of new EU sanctions and synchronized regimes with Ukraine, even companies that previously considered themselves "low-risk" may face the need for urgent transformation of corporate structures and compliance processes.
Sanctions in metallurgy are not just formal restrictions but a complex of new requirements for transparency, risk management, control of transactions with precious metals, and the implementation of ESG standards. International sanctions in metallurgy change not only the geography of exports but also the very logic of business conduct: from Due Diligence of partners to compliance automation and restructuring supply chains.
Owners, top managers, and compliance officers face a challenge: how to not only survive but also maintain export margins under sanctions, minimize sanction risks for metallurgy, and ensure sustainability under new conditions.
In this article, I, Nikita Veremeev, share the experience of COREDO: we will analyze key changes for metallurgical companies in 2025–2026, show how regulations in the metallurgical business and metallurgy compliance become strategic assets, and offer practical solutions for adapting to the new realities. If you want not just to follow trends but to manage them, I recommend reading the material to the end.
Changes for metallurgy: sanctions, regulation
Changes for metallurgy in 2025–2026 are largely defined by the tightening of sanctions and increased government regulations from key global economies. New trade restrictions, updated sanctions lists, and regulatory barriers significantly change the working conditions of metallurgical companies, requiring the industry to adapt to new risks and challenges.
Expert summary: what is it?
2025 and 2026 became a turning point for regulating the metallurgical business: tightened requirements for corporate structures, compliance, and AML, enhanced control of international supply chains, and ESG standards came to the forefront. COREDO's experience confirms: companies that timely integrated sanctions compliance and automated KYC/AML not only retained access to key markets but also increased their investment attractiveness.
EU sanctions: from the 18th to the 21st package and Ukraine
The 18th EU sanctions package was adopted in July 2025. It was followed by the 19th package in October 2025, the 20th in April 2026 and the 21st in July 2026. In October 2026 the EU adopted its largest-ever set of listings: almost 1,600 individuals and entities. For metallurgy, the 20th package added import bans on metals, chemicals and minerals not yet under sanctions, while the 21st locked in the diversification of metal ore imports and restricted exports of certain metal powders and alloys. In April 2026 the EU also activated its anti-circumvention tool for the first time, against Kyrgyzstan. The synchronization of EU and Ukrainian sanctions means that even transactions through third countries now require deep partner verification and the integration of sanctions lists into business processes.
The COREDO team implemented projects to adapt metallurgical holdings' corporate structures to new requirements:
for example, for a client with assets in the EU and Asia, an automatic verification module for all partners against the EU and NSDC sanctions lists was implemented, reducing the risks of secondary sanctions and account blocking.
In the face of tighter regulation, this requires even more attention to complying with AML and KYC standards, which are becoming an integral part of metallurgical companies' operations.
AML and KYC requirements in metallurgy
FATF standards and EU AML rules set increasingly strict expectations for the metal trade: KYC procedures for all new partners and regular monitoring of operations with precious metals, investment coins, and bullion have become the norm.
Anti-money laundering legislation for metallurgy requires the implementation of automated compliance platforms, integration of bank monitoring, and control of operations with valuables.
COREDO's practice shows: automation of AML/KYC significantly reduces costs and minimizes the human factor. In one case for an international trader, transaction monitoring tools through counterparty banks were implemented, allowing the detection of suspicious operations in real-time and preventing fines for sanctions violations.
ESG and supply chain transparency
ESG requirements and new reporting standards are becoming increasingly important for metallurgical companies operating in the EU, UK, Singapore, and Dubai. International reporting standards require transparency of the corporate structure, disclosure of ultimate beneficiaries, and control of the entire supply chain from ore extraction to the export of finished products.
A solution developed at COREDO allows integrating ESG indicators and reporting according to international standards into a single compliance platform, ensuring supply chain transparency and compliance with both European and Asian regulators' requirements.
Metal exports under sanctions: risks and markets
Metal exports under sanctions inevitably face new risks and a forced reorientation of markets. Tough restrictions from the EU and other countries require companies to seek alternative routes and reduce export margins, changing the usual industry structure.
Expert summary: what is it?
Metal exports under sanctions: an area of increased risks and new opportunities. Restrictions now extend not only to traditional EU markets but also to transactions with rare earth metals, precious metals and stones, investment coins, and bullion. COREDO's experience shows: smart market diversification and transaction structuring allow maintaining export margins even under stricter sanctions.
Export restrictions: countries, products, banks
Sanctions in metallurgy introduce direct and indirect restrictions on trade in metals. The EU already banned imports of processed aluminium goods from Russia, and the 16th package (February 2025) added a phased ban on primary aluminium. By the end of 2026, no Russian aluminium can be imported into the EU. The 20th package extended import bans to further metals and minerals. Particular attention is paid to the control of counterparty banks in metal transactions:
most European and Asian banks conduct in-depth monitoring of the origin of funds and the supply chain, and in some jurisdictions (e.g., Singapore and the UK), investment restrictions have been introduced for metallurgical companies associated with sanctioned entities.
The COREDO team successfully implemented projects to structure cross-border metal transactions through SPVs and holding companies in the EU and Asia, allowing clients to minimize the risks of payment blocking and maintain access to international supply chains.
Rules for deals with gold and diamonds
Control over transactions with precious metals has tightened: now deals with gold, diamonds, investment coins, and bullion require mandatory compliance checks and monitoring of operations with precious metals. New rules for gold and diamond transactions have been introduced, including control of jewelry operations, mandatory disclosure of ultimate beneficiaries, and integration of data into international registries.
In one of COREDO's cases for a client from the EU, a control system for operations with investment coins and bullion was implemented, allowing tracking asset movements at all stages of the transaction and ensuring compliance with new AML/KYC requirements.
Circumventing sanctions: alternative markets
Under current sanctions, metallurgy is actively seeking alternative markets: Asia, Africa, and the Middle East are becoming new centers of demand for metal products. However, schemes for bypassing sanctions in metallurgy require special caution: structuring transactions through "nesting doll" firms, alternative supply routes, and using SPVs must be accompanied by thorough due diligence and legal audits.
COREDO's practice confirms: only legitimate structuring and transparent corporate structure can avoid secondary sanctions risks and maintain business investment attractiveness.
Sanctions risk verification: due diligence and automation
Sanctions risk verification today requires not only deep due diligence but also modern automation tools to identify potential threats at the early stages of working with counterparties.
This approach allows companies to minimize the likelihood of violating sanctions legislation and reduce operational and reputational risks.
Below are the key stages of comprehensive verification and the role of the expert summary in this process.
Expert summary: what is it?
Sanctions risks for metallurgy today demand not just formal compliance but comprehensive risk management: from counterparty checks to automation of compliance processes and integration of digital platforms for transaction monitoring.
COREDO's experience shows that timely due diligence of partners and automation of metal transactions checks significantly reduces the likelihood of fines and legal disputes.
Counterparty verification, new rules and methods
Counterparty verification metallurgy: a key element of managing sanctions risks. New requirements include mandatory compliance checks for metal transactions, integration of the EU and NSDC sanctions lists, and the use of digital platforms for counterparty verification (e.g., LIGA360).
Particular attention is paid to identifying toxic company ties and risks for new partners in metallurgy.
In one of the implemented COREDO projects, automatic integration of sanctions lists into the onboarding process of new partners was introduced, allowing a client from the Czech Republic to identify potential risks at the preliminary analysis stage of the deal.
Compliance and transaction monitoring automation
Modern compliance tools for metallurgy allow automating compliance processes, monitoring transactions through banks, and integrating AML/KYC procedures. Innovative risk management methods, such as automatic transaction scoring and monitoring operations with precious metals, have become an obligatory standard for companies operating in the EU, Asia, and Africa.
COREDO's solution for compliance process automation includes integrating digital platforms for counterparty verification, saving time and resources, and minimizing the human factor in identifying sanctions risks.
Fines for sanction violations: judicial practice
Sanctions violations in metallurgy can lead to court cases and substantial fines. Special attention is paid to the subsidiary liability of deal participants and the corporate structure of metallurgical holdings.
COREDO's practice shows that only regular audits of connections and corporate structure transparency minimize the risks of legal disputes and fines for violating the sanction regime.
Business registration in metallurgy under sanctions
In today’s environment, business registration in the metallurgy sector faces significant restrictions related to international sanctions and industry regulations. Understanding the nuances of legal regulation and the specifics of the current sanctions policy becomes critically important for those planning to work in this sector.
Expert summary: what is it?
company registration in the metallurgical sector of the EU/Asia today requires not only compliance with formal procedures but also a deep understanding of new requirements for corporate structure, compliance, and tax burden optimization. COREDO's experience in supporting international projects confirms: smart business structuring is the key to sustainability and investment attractiveness under sanctions.
Thanks to this approach, the chosen jurisdiction and company form will best match business goals, which we will consider further.
Company registration in the EU and Asia
Today, the registration of metallurgical companies in the EU and Asia entails the preparation of an extended package of documents: charter, information about ultimate beneficiaries, confirmation of source of funds, licenses for certain activities, and also Opening bank accounts in jurisdictions with a high level of regulation. Requirements for founders have tightened: a check for absence in sanctions lists and confirmation of the legality of capital origin are mandatory.
The COREDO team supports clients at all registration stages: from choosing the optimal jurisdiction (Czech Republic, Slovakia, Cyprus, Estonia, Singapore, Dubai) to obtaining licenses and opening bank accounts, ensuring full compliance with new requirements.
Tax optimization and business compliance
Tax burden optimization for metallurgical companies is impossible without smart corporate structuring: the use of SPVs, holdings, "nesting doll" firms, and transparent ownership schemes allows minimizing risks of subsidiary liability and investment restrictions.
Special attention is paid to compliance with new requirements for the corporate structure of metallurgical companies and the integration of compliance procedures at all levels.
COREDO's solutions include auditing corporate structure, implementing due diligence, and compliance automation, allowing clients not just reduce tax burdens but also increase transparency for international partners and banks.
Risks of new partners for business
Risks for new partners in metallurgy and toxic company ties are coming to the forefront: sanctions lists are updated regularly, and judicial practice on subsidiary liability is becoming increasingly strict. Integrating due diligence and conducting regular audits of ties is a mandatory element of business protection.
The COREDO team has implemented cases for identifying and eliminating toxic ties in clients' corporate structures, preventing account blocking, and maintaining access to international markets.
What metallurgical companies should do under sanctions
Sanctions continue to exert significant pressure on metallurgical companies facing new restrictions and challenges in conducting foreign economic activities. In the current situation, it is especially important to understand what metallurgical companies should do under sanctions to maintain business sustainability and find new opportunities for growth.
Expert summary: what is it?
In the face of tightening regulation of the metallurgical business and increasing sanction risks, only the implementation of best compliance practices, process automation, and strategic risk management allow companies not only to survive but to scale. COREDO's experience confirms: timely adaptation to new requirements ensures business sustainability and profitability.
Supply chain transparency: how to meet standards
Supply chain transparency in metallurgy: a key factor in compliance with international reporting standards and ESG.
The use of digital platforms for monitoring supply chains, integration of ESG indicators, and regular reporting according to international standards allow companies to maintain partner trust and access to financing.
COREDO implements solutions that allow automating the collection and analysis of data across the entire supply chain, ensuring transparency and compliance with Worldsteel, European Commission, and FATF requirements.
Technological innovations and automation
Technological innovations in metallurgy for bypassing sanctions include compliance process automation, implementation of digital platforms for counterparty verification and monitoring operations with precious metals. Compliance tools for metallurgy make it possible to identify risks in real-time and react quickly to changes in sanctions regulation.
In one of COREDO's projects for a client from the UK, an automated system for monitoring metal transactions was implemented, reducing compliance costs by 30% and increasing decision-making speed.
Short-term and long-term ROI strategies
Under current sanctions, metallurgy requires a strategic approach to investment and business scaling. Export margins under sanctions are maintained only through market diversification, corporate structure optimization, and implementation of innovative risk management methods. ROI in the metallurgical business under sanctions depends on the company's ability to quickly adapt to new requirements and leverage alternative market opportunities.
COREDO supports clients at all stages of business scaling: from company registration in new jurisdictions to the implementation of automated compliance solutions and tax burden optimization.
Recommendations for metallurgical companies
| Key Change | Practical Actions | Main Risks | Tools and Solutions |
|---|---|---|---|
| EU sanctions packages 18–21 | Check counterparties, update KYC | Secondary sanctions, account blockage | LIGA360, integration of sanctions lists |
| New AML/compliance requirements | Implement automation, train personnel | Fines, loss of license | Compliance platforms, training |
| Metal export restrictions | Market diversification, transaction structuring | Market loss, reduced margins | Alternative routes, SPV |
| Corporate structure requirements | Structure optimization, connection audit | Subsidiary liability | Due diligence, legal audit |
Checklist for a metallurgical company
- Conduct an audit of corporate structure and connections to ensure compliance with new sanctions requirements.
- Implement automated platforms for counterparty verification and transaction monitoring.
- Update internal AML/KYC policies and train staff on new standards.
- Ensure supply chain transparency and integrate ESG indicators into reporting.
- Develop a strategy for market diversification and transaction structuring through SPVs and holdings.
- Regularly conduct due diligence on new partners and audit toxic connections.
- Monitor judicial practice and updates of EU and NSDC sanctions lists.
If you wish to receive an individual consultation, conduct an audit, or implement a comprehensive compliance solution: the COREDO team is ready to offer the best practices and tools proven in international markets.