The tenth EU sanctions package against Russia aims to prevent circumvention of sanctions – export prohibitions included

The tenth EU sanctions package against Russia contains further expansion, but also aims to intervene in the circumvention of sanctions. Finnish Customs has conducted control operations and observed potential attempts of sanctions circumventions.

The tenth sanctions package involves an interventions against sanctions circumventions. The package prohibits exports of dual-use products as well as firearms and firearm supplies from the EU to Russia via third countries. Dual-use products are goods that can be used for both civilian and military purposes. 

The purpose of the prohibition is to prevent such products from remaining in Russia during transit. 

Furthermore, the new sanction package introduces ever-stricter export prohibitions on products that could serve Russia’s military, industrial and technological capabilities. The new export prohibitions cover for example new steel products, electric steering devices and to a broader extent cameras, antennas and optical devices. In addition, snowmobiles are now under export prohibition, and exporting them to Russia regardless of value is prohibited.

As for import bans, sanctions now cover more oil products and refined petroleum products, such as synthetic rubber and bitumen. Stricter import and export prohibitions enhance the effect and enforcement of sanctions.

Finnish Customs has observed possible attempts of sanctions circumventions through non-EU countries

Customs has paid special attention to enabling the sanctions against Russia to work as efficiently as possible, and to preventing their circumvention. 

– We have pointed out phenomena that we have observed so they can be addressed also at the level of legal provisions. Based on our enforcement operations, we have noted potential attempts at sanctions circumventions for example through countries outside the EU. We are also monitoring increased exports to Russia’s southern neighbouring countries such as Kazakhstan, Kyrgyzstan and Armenia. Volumes of exports to these countries have increased significantly, up to several hundred per cent. Indeed, it can be assumed that not all products end up in their intended destinations, says Mr Sami Rakshit, Director of the Enforcement Department.

– We have observed that some products under sanctions may stay in Russia during transit. In some cases, there are also indications of products first being exported to countries outside the EU, and the continuing to Russia after reaching their declared destination. We have countered potential attempts at sanctions circumventions with various enforcement measures, and we have for example uncovered cases involving dual documentation where there have been documents for exporting products both to a non-EU country and to Russia, Rakshit says.

The new EU sanctions were published in the Official Journal of the European Union on 25 February 2023 and they enter mainly into force on 26 February 2023.

Press release by the Ministry for Foreign Affairs (25 February 2023): EU expands sanctions in response to Russia’s ongoing war of attack 

The European Union has imposed extensive import and export sanctions against Russia due to the attack on Ukraine. As the implementing authority, Customs enforces sanctions as a part of normal customs enforcement