We welcomed the 17th EU package of sanctions against Russia, which targeted, among other things, the shadow fleet. However, the package should be stronger because sanctions are still not enough. For example, the European sanctions on exports to Russia, the terrorist state, are too often being circumvented. Sometimes through third countries. How?

The Centre for Eastern Studies (OSW) examined the exports of one crucial good: tapered roller bearings, which are key parts of tracked vehicle drives[1]. The sanctions on the EU export of such dual-use goods - ones used both for civilian and military applications - to Russia have been proven to be effective and decreased almost to zero. But only officially. After 2022, their export increased, especially to Turkey (mainly from Germany) and Kazakhstan (now mainly from Germany and France). The export graph correlates with regulatory actions. These two countries exported an additional 3 thousand tons of tapered bearings per year to Russia compared to the average of previous years. And probably more - Kazakhstan stopped publishing data last year, and Turkey exports through third countries, such as Iran, Belarus and Uzbekistan. You can read the full analysis on OSW website.

Türkiye export to Russia grew the most in case of tapered rollered bearings.

*Source: Bartłomiej Pierzchała. Finding our bearings: tracking circumvention of EU dual-use sanctions on Russia. Center for Eastern Studies. 14.04.2025.*
Read the full publication: https://www.osw.waw.pl/sanctions/

This data on circumvention of sanctions is easily accessible and also concerns other goods. Probably the most "famous" example is vehicles. Export of cars from the EU to Kyrgyzstan grew 80 times after the full-scale Russian invasion, to Kazakhstan over 6 times, and about 3 times to Uzbekistan[2]. These countries, though officially supporting EU sanctions, are known for helping Russia in bypassing them and supporting its military industry by exporting, for example, cotton pulp needed to produce gunpowder[3]. The EU had a lot of time to adapt its countermeasures, as the circumvention of sanctions was practised by third-country companies before, for example, the trucks from Sweden were transported to Assad’s Syria via Jordan, thus bypassing the EU regulations [4].

The weakness of Europe’s diplomacy regarding the bypassing of sanctions has not only an impact on the Russian economy and military industry, but also contributes to the strengthening of authoritarian regimes in Central Asia. Even Kyrgyzstan, previously considered relatively democratic, has, among others, closed down human rights media outlet Kloop that was conducting investigations throughout the region[5]. The influx of huge amounts of money from Russia and dependence on the totalitarian terrorist state, with the simultaneous decreasing external cost of authoritarianism and lack of counteraction from the West, has resulted in the consolidation of Sadyr Japarov's authoritarian power.

*Ten out of seventeen sanction packages was implemented in the first year.*

*The pace of introducing subsequent sanctions packages has slowed down - it must be increased so that Russia and its economic partners do not have time to find legal loopholes.*

It should force Europe to act and increase regulation. The 16th package of sanctions has anti-circumvention regulations against Belarus, which is a step in the right direction. But there is a need for stronger diplomatic pressure on all the countries that allow the circumvention of sanctions needs, as well as the better identification and fines on individuals and companies within EU that are benefitting from bypassing the sanctions. Sanctions enforcement needs to be improved and made legally binding to be really effective. We wait for it in the next sanction package that should come very quickly, so the needed regulations is implemented as soon as possible, and russia and its allies doesn’t have time for finding any loopholes.

Igor Skórzybót, CDN Secretary General

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[1] Bartłomiej Pierzchała. Finding our bearings: tracking circumvention of EU dual-use sanctions on Russia. Center for Eastern Studies. 14.04.2025. https://www.osw.waw.pl/sanctions/

[2] Bolot Temirov, Eldiyar Arykbaev, Anastasia Korotkova, Eloise Layan. ‘We Know No Borders’: How Kyrgyzstan Became a Hub for Sanctioned Car Exports to Russia. OCCRP. 26.02.2025. https://www.occrp.org/en/feature/we-know-no-borders-how-kyrgyzstan-became-a-hub-for-sanctioned-car-exports-to-russia

[3] Anton Shvets. White and fluffy death. How Uzbekistan and Kazakhstan help Russians produce gunpowder. Ukrainska Pravda. 10.01.2024. https://www.pravda.com.ua/eng/articles/2024/01/10/7436569/

[4] Ali Al Ibrahim, Selma Mhaoud. The Secretive Supply Chain Sending EU Trucks to Syria. OCCRP. 24.09.2024. https://www.occrp.org/en/investigation/design-test-the-secretive-supply-chain-sending-eu-trucks-to-syria

[5] Read more in: Anne Applebaum. Autocracy, Inc.: The Dictators Who Want to Run the World. Agora. 2024. P. 59-61 (in Polish edition).

17th EU package of sanctions is not enough.

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