The British Office of Trade Sanctions Implementation (OTSI) has published a guidance for businessmen to help companies identify Russian methods of evading sanctions.
The document lists countries that require special attention, as sanctioned goods can be imported into Russia via these countries: Armenia, China (including Hong Kong and Macau), India, Kazakhstan, Kyrgyzstan, Malaysia, Serbia, Thailand, Turkey, the United Arab Emirates, Uzbekistan, and Vietnam.
OTSI has reported that trade between the UK and Russia has decreased to historic lows due to the imposition of sanctions. The UKTI has also stated that over £20 billion of UK trade with Russia is now subject to sanctions.
However, Russia is actively seeking to circumvent these sanctions by procuring Western military, dual-use, and other critical goods through third countries, including beyond the battlefield technologies.
Russia has demonstrated a willingness to use deceptive tactics, such as indirect shipping routes, falsifying the intended use of traded goods, and relying on professional evasion networks, to evade established export controls and sanctions enforcement. These tactics are constantly evolving, sometimes without the knowledge of partner countries.
