Working Group Paper #16: 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. 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 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.