New research on Russia's attempts to circumvent export control restrictions.

26 January 2024
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New research on Russia's attempts to circumvent export control restrictions.

The Yermak-McFaul Expert Group on Russian Sanctions has developed new research. It focuses on Russia's attempts to circumvent export control restrictions on military and dual-use goods and software.

Together with the Kyiv School of Economics, a document has been prepared that exposes the ways in which military and dual-use goods are supplied to Russia. The paper analyzes nearly 2,800 foreign components found in Russian military equipment and the companies responsible for their production. Among the main points:

  • After the introduction of restrictions in 2023, imports of military goods to the Russian Federation recovered by 90% of the volume before the full-scale invasion.
  • Imports of dual-use goods decreased by almost 29%, which indicates the success of export control measures if they are observed and properly applied.
  • Products from more than 250 Western companies were found in samples of destroyed or trophy Russian weapons.
  • In the first ten months of 2023, Western companies supplied critical components to Russia totaling $2.9 billion.
  • Export controls remain one of the most powerful instruments of influence as Russia tries to replace critical goods, particularly in the field of modern electronics.
  • The document emphasizes that it is increasingly difficult to trace goods after sale. Control over the supply chain should start with the first sale to a distributor.
  • Improving the situation with export control compliance depends on cooperation with the private sector. Especially with producers of goods that can be used in the Russian military-industrial complex. The key is to introduce export control compliance procedures for corporations.
  • Law enforcement agencies in Western countries, particularly in the European Union, need to be better equipped to implement and enforce export controls. Multilateral cooperation is important for the effectiveness of measures.

Export control measures will be effective only if they outpace Russian attempts to circumvent them. These measures should be aimed at addressing gaps in export control policy, strengthening corporate responsibility, countering circumvention attempts by third countries, and strengthening institutions and international cooperation.

In its new study, the International Working Group considered the analysis and investigations conducted by the Economic Security Council of Ukraine (ESCU), particularly concerning computer numerical control machines.

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