Sanctions circumvention. It is one of the key topics of the moment.
It is a routine question for people to ask which countries provide a circumvention risk. It is also a common perception that enforcement of sanctions circumvention is lacking.
Based on the material in this blog we have listed out below the more than 40 examples where of recent enforcement of sanctions circumvention on a third-country by third-country basis. Where a particular case involved circumvention via several countries they are listed separately.
The vast majority of the examples come from the period from 2022 to the present.
Bahrain
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- February 2019: Dutch convictions for Iran exports through Germany and Bahrain.
Belarus
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- March 2024: German arrests for exports to Russia through Belarus.
Central Asia
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- September 2023: Latvian investigation into Russian exports through central Asia.
China
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- September 2023: Latvian investigation into Russian exports through China.
- February 2020: Dutch seizure of goods being exported to North Korea via China.
Dubai
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- April 2024: Irish investigation including the routing of payments through Dubai.
- January 2024: Dutch arrests for exports to Russia involving Dubai.
- July 2023: Swiss investigation into oil company trading through Dubai subsidiary.
- June 2022: Dutch conviction for Iran exports via Dubai.
- September 2017: Dutch conviction for Iran exports via Dubai.
Georgia
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- November 2023: Lithuanian investigation for exports to Russia involving Georgia.
Hong Kong
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- March 2024: German charges for exports to Russia through Hong-Kong.
- January 2024: Dutch arrests for exports to Russia involving Hong Kong.
- October 2023: German arrests for Russian exports through Hong Kong.
Kazakhstan
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- April 2024: Lithuanian investigation into exports to Belarus via Kazakhstan.
- March 2024: Polish investigation into Belarus imports purporting to be from Kazakhstan.
- March 2024: Finnish investigation into alleged exports to Russia via Kazakhstan.
- February 2024: Latvian investigation into Russian imports purporting to be from Kazakhstan.
- November 2023: Lithuanian investigation for exports to Russia involving Kazakhstan.
- July 2023: Dutch arrest for Russian exports through Kazakhstan.
- May 2023: Lithuanian investigation into imports Russian and Belarusian imports purporting to be from Kazakhstan.
Kyrgyzstan
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- April 2024: Lithuanian investigation into exports to Belarus via Kyrgyzstan.
- March 2024: German charges for exports to Russia through Kyrgyzstan.
- February 2024: Latvian investigation into Russian imports purporting to be from Kyrgyzstan.
- November 2023: Lithuanian investigation for exports to Russia involving Kyrgyzstan.
- July 2023: Dutch arrest for Russian exports through Kyrgyzstan.
- May 2023: Lithuanian investigation into imports Russian and Belarusian imports purporting to be from Kyrgyzstan.
Mongolia
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- July 2023: Dutch arrest for Russian exports through Mongolia.
Switzerland
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- August 2023: German arrests for arms exports to Russia via Switzerland.
Tajikistan
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- November 2023: Lithuanian investigation for exports to Russia involving Tajikistan.
Turkey
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- July 2023: Czechian investigations into Russian machinery exports through Turkey.
- July 2023: Dutch arrest for Russian exports through Turkey.
- June 2023: Czechian investigation into Russian machinery exports through Turkey.
- February 2023: German raids on company for Russian exports through Turkey.
- June 2022: Dutch conviction for Iran exports via Turkey.
- February 2022: Dutch conviction for ISIS payments through Turkish intermediaries.
- September 2017: Dutch conviction for Iran exports via Turkey.
Turkmenistan
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- November 2023: Lithuanian investigation for exports to Russia involving Turkmenistan.
United Arab Emirates
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- July 2023: Dutch arrest for Russian exports through the UAE.
Uzbekistan
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- November 2023: Lithuanian investigation for exports to Russia involving Uzbekistan.
- July 2023: Dutch arrest for Russian exports through Uzbekistan.