Sanctions Evasion On The Rise
- Arne Mielken
- 1 day ago
- 4 min read
UK and EU components are still ending up on Russian battlefields. Here's how sanctions evasion is happening—and what you must do now.
As a sanctions compliance professional, you're told the system is working. That our UK, EU, and U.S. sanctions are biting. But the reality—laid bare by Sky News and Ukrainian battlefield evidence—is starkly different. Despite the so-called "toughest sanctions regime in history," UK-origin components are making their way to Russia, helping fuel its war against Ukraine. If you're managing export controls or sanctions compliance, this isn't just troubling—it demands action.
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Key Questions Covered in This Blog
Are UK and EU-origin goods still making it to Russia, despite sanctions?
What concrete evidence shows sanctions evasion is happening?
How are dual-use items circumventing direct routes and re-entering Russia?
Which countries are being used as trans-shipment hubs?
What does this mean for your export controls and sanctions compliance programs?
What should companies do to prevent inadvertent violations?
More Information
"Sanctions aren’t just about what we prohibit—they’re about what we enable through blind spots in enforcement. If British components are killing Ukrainians, the system is failing. It’s time for honest reflection and tough corrective action." Arne Mielken, Managing Director, Customs Manager Ltd
Abbreviations Used In This Blog
OFSI – Office of Financial Sanctions Implementation (UK)
OFAC – Office of Foreign Assets Control (U.S.)
EU – European Union
UK – United Kingdom
USA – United States of America
G7 – Group of Seven advanced economies
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Are UK and EU-origin goods still making it to Russia, despite sanctions?
Yes. Despite official trade data showing near-zero exports of dual-use goods to Russia, real-world evidence shows these goods are arriving via third countries. Sky News’ latest investigation, backed by field reporting and trade data, confirms that items banned for export—including radar systems and drone components—are reappearing across Russia’s borders.
What concrete evidence shows sanctions evasion is happening?
On-the-ground footage: British-made cars and other sanctioned goods have been filmed crossing into Russia through land borders in Central Asia.
Battlefield recovery: Ukrainian military units have retrieved downed drones and missiles containing UK and EU-manufactured components. These parts, originally restricted under the sanctions regime, were never supposed to be there.
These aren’t isolated incidents—they’re patterns.
How are dual-use items circumventing direct routes and re-entering Russia?
The supply chains have adapted. Instead of shipping directly to Russia, exporters—whether knowingly or not—send goods to Kazakhstan, Kyrgyzstan, Armenia, Uzbekistan, and Georgia. These nations have seen sharp rises in imports of dual-use goods. In some cases, export volumes have more than doubled compared to pre-war levels. Once goods reach these countries, they are quietly re-exported to Russia—either legally under local regulations or through grey channels.
Which countries are being used as trans-shipment hubs?
Alongside Central Asian republics, the United Arab Emirates (UAE) and Turkey have emerged as key waypoints. These nations are seeing spikes in imports of sensitive goods from the UK and EU. The numbers don’t lie: in the last nine months alone, flows of such goods have risen 9% month-on-month, and are now over 111% above pre-invasion levels.
These figures are a flashing red light for compliance teams.
What does this mean for your export controls and sanctions compliance programs?
You need to rethink your risk assessment models. Traditional destination-based due diligence is no longer enough. Sanctions compliance now demands end-to-end supply chain scrutiny—especially where third-country trans-shipment is likely. You must identify where goods might be diverted and how to prove end-use integrity.
What should companies do to prevent inadvertent violations?
Step 1: Implement enhanced due diligence for transactions involving Central Asia, the Caucasus, UAE, and Turkey.
Step 2: Revise your screening logic to include red flag indicators tied to suspicious end-users, resellers, and shipping patterns.
Step 3: Train your team to recognise sophisticated circumvention schemes.
Step 4: Work with logistics providers who understand and comply with export control regulations.
Step 5: Regularly audit post-shipment data to verify goods end up where they are supposed to.
Arne’s Takeaway
Sanctions are only as effective as their enforcement. If our components are turning up in Russian weapons, we are complicit—by omission if not by intent. It’s time for every exporter, broker, and compliance team to confront this reality. You can't afford to ignore trans-shipment risk. Tighten your controls now.
Expert Recommendations
Conduct enhanced risk mapping for all high-risk destinations.
Subscribe to real-time export compliance databases and alerts.
Build cross-functional export control teams with legal, trade, and operations.
Join our training on trans-shipment evasion tactics (new dates at www.customsmanager.org/events).
Sources & Further Information
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Disclaimer: This blog is for educational purposes only and does not constitute legal advice. Always consult with a qualified export controls or legal professional regarding your obligations.
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