Challenges of Export Controls Enforcement: How Russia continues to import components for its military production

In the aftermath of Russia’s full-scale invasion of Ukraine, a coalition of countries – including European Union member states, the United States, United Kingdom, Japan, South Korea, and others—imposed unprecedented export controls on the Russian Federation, including with regard to dual-use goods. The objective is to deprive the aggressor of critical inputs such as high-tech electronics for its war effort and military industry. Export controls, however, present major enforcement challenges due to the complexity of global supply chains, the fact that large economies such as China are not part of the sanctions coalition, and because of a lack of experience and institutional resources on the part of the coalition countries. Therefore, it is not surprising that Russia continues to be able to acquire large amounts of the inputs that it needs for its military production. In the first ten months of 2023, imports of what the U.S., EU, UK, and other partners of Ukraine have identified as priority battlefield goods reached $8.77 billion—only a 10% decline compared to the pre-sanctions period. In this report, we outline well-known issues, including third-country circumvention schemes, but focus in particular on the role of producers from export controls coalition countries whose products are manufactured abroad and make their way to Russia due to insufficient compliance efforts by the private sector. Almost half of all of Russia’s imports of the goods in question in 2023 ultimately stem from producers from the coalition. Fundamentally, our analysis shows that the issues identified in previous research continue to plague export controls implementation and enforcement.