Five schemes Russia uses to circumvent sanctions since 2014
"Svidomi" in cooperation with Trap Aggressor talk about several schemes used by the Russian Federation to circumvent sanctions.
Trade in dual-purpose goods*
The German company Bosch insisted that it sells automotive equipment for peaceful purposes only, but its equipment was found in Russian infantry fighting vehicles.
On February 25, 2022, the European Union banned the import of dual-purpose items, except those for humanitarian needs, medical equipment, and media. However, the list of exceptions creates room for manipulation. Therefore, Russia can continue to purchase equipment for "medical purposes", but use it for military purposes.
*Dual-purpose goods are items that are used for both peaceful and military purposes at the same time.
Absence of a complete list of bans on activity
The Norwegian company Statoil continued to develop limestone reservoirs in Russia after the introduction of sanctions in 2014.
Before the sanctions, Statoil announced the "development of shale deposits". After the ban on this type of energy resource development, the company published information that it will help in the development of "unconventional deposits" — the limestone ones. The company could likely take advantage of the loophole and reclassify the deposits to hide its activities.
Ignorance as a public stance
Enerpac Heavylifting, which is part of the American international company Actuant, installed elevators on the Crimean Bridge in 2017.
The company used the regulation of the European Council of July 30, 2014: if the party "did not know and did not have reasonable grounds to suspect that its actions would violate the measures set out in the Regulation", then it can refer to this provision to prove its innocence.
Subsidiaries of sanctioned enterprises
Sberbank and VTB have created subsidiaries in Europe to continue operating despite the sanctions. "Sberbank" was able to attract €1.6 billion through deposits in Europe, and VTB — €3.9 billion. Sberbank Europe AG has been working under this scheme since July 2014.
The EU, the US, and the UK in most cases impose sanctions on the big players to more easily monitor activities and punish violations. However, subsidiaries may continue to operate in European countries, emphasizing independence from the parent company.
Hiding the product's country of origin
"You can bring a ton of detergent and package it in Ukraine, but you can't bring a pack of it, because a pack is subject to sanctions, but a ton is not. Fish, caviar, seafood, tea, coffee — almost all companies have placed their packaging equipment in Ukraine," explained the general director of the trade network suppliers' association.
This is how Russian goods entered Ukraine after the 2015 embargo. After the introduction of a full embargo in 2022, Russia can no longer use this scheme.
How to stop sanctions circumvention schemes?
- Introduce a full embargo on the export of dual-purpose goods to the Russian Federation.
- Ban investment in all types of energy resources, including limestone deposits.
- Introduce liability for violation of sanction norms into the European Council regulation from July 30, 2014.
- Introduce sanctions against the subsidiaries of those legal entities that are already under sanctions.
- Extend a full embargo on the import of goods from Russia to Ukraine for the next 10 years.