The case

Cracking Down on (international) Third‐Party Intermediaries Used to Evade Russia‐Related Sanctions and Export Controls: “Over the year following Russia’s illegal and unprovoked war against Ukraine, the U.S. government has used its economic tools to degrade Russia’s economy and war machine. Along with international partners and allies, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) and the Department of Commerce’s Bureau of Industry and Security (BIS) have imposed sanctions and export controls of an unprecedented scope and scale in an effort to degrade Russia’s ability to wage its unjust war and to prevent it from taking military action elsewhere. The Department of Justice (DOJ) has matched these unprecedented restrictions with equally unprecedented enforcement efforts to aggressively prosecute those who violate U.S. sanctions and export control laws, led by the work of Task Force KleptoCapture. Despite these efforts, malign actors continue to try to evade Russia‐related sanctions and export controls. One of the most common tactics is the use of third‐party intermediaries or transshipment points to circumvent restrictions, disguise the involvement of Specially Designated Nationals and Blocked Persons (SDNs) or parties on the Entity List in transactions, and obscure the true identities of Russian end users.“

Source: Treasury

The commentary

Around one year after the invasion the U.S. government made it clear that its efforts to support Ukraine are continued for the foreseeable future. One of the focus points are third-party intermediaries used to evade sanctions. It can be expected that Europe, UK etc. follow the course.

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