The third-party problem: Countering sanctions circumvention

In response to the Russian full-scale invasion of Ukraine in February 2022, the European Union (EU) in close coordination with its like-minded partners and allies has imposed unprecedented sanctions. To date, eleven packages have been approved, targeting 245 entities and 1,550 individuals and covering a wide range of key sectors, goods and services. Likewise, the United States has imposed over 3,000 sanctions on Russia with the intent of weakening Moscow’s ability to wage war and depressing its export income.

Sanctions are having a very tangible impact with Russia losing crucial revenue and growing desperate to procure a wide range of goods. Nevertheless, Western goods and components continue finding their way to Russia, albeit through increasingly complex routes and schemes. To that end, sanctions coordinators from the EU and the United States have engaged in extensive outreach, sometimes jointly, with Türkiye, the United Arab Emirates, Kyrgyzstan, Kazakhstan, Uzbekistan, Armenia, Georgia and Serbia.

How extensive is sanctions circumvention, and how is the cooperation with third countries going? What is the role of US and EU companies in broader circumvention patterns and what can be done to stop this? What are feasible steps to strengthen compliance, and should such measures look to convince or coerce? And how should the EU, US, and their partners coordinate their response?

Finally, how should Western allies and partners engage China, which is estimated to supply around seventy percent of high-tech products of military capability to Russia? What additional steps should we consider to ensure compliance across new and existing measures?

Join us at 9:30 am on October 23 for an expert panel discussion with Ambassador David O’Sullivan, International Special Envoy for the Implementation of EU Sanctions, and James O’Brien, Assistant Secretary for European and Eurasian Affairs and former Head of the Office of Sanctions Coordination at the US Department of State. This conversation is moderated by Kimberly Donovan, Director of the Economic Statecraft Initiative at the Atlantic Council.

Opening remarks

Jörn Fleck
Senior Director, Europe Center
Atlantic Council

Speakers

David O’Sullivan
International Special Envoy for the Implementation of EU Sanctions
European Commission

James O’Brien
Assistant Secretary for European and Eurasian Affairs and Former Head of the Office of Sanctions Coordination
US Department of State

Moderator

Kimberly Donovan
Director, Economic Statecraft Initiative, GeoEconomics Center
Atlantic Council

At the intersection of economics, finance, and foreign policy, the GeoEconomics Center is a translation hub with the goal of helping shape a better global economic future.

Learn more