7. Stop sanctions circumvention
Violations of the sanctions help Russia to continue the war in Ukraine. With Corisk, a consultancy, the NHC conducted targeted advocacy efforts at states and businesses and contributed to media stories to shed light on sanctions circumvention.
The Russia sanctions, first adopted in 2014, include both targeted and sectorial sanctions to undermine the Russian economy, finances, and trade and, thereby, their ability to wage an illegal war. Ultimately, the Russia sanctions are intended and designed to respond to Russia’s international crimes.
‘The Russia sanctions are, at the core, a human rights instrument, intended to defend international law. It is about our security – and yours. We should all support, enforce, and comply with them.’
NHC’s colleague Oleksandra Matviichuk, director of the Nobel Peace Prize Laureate, Ukraine’s Centre for Civil Liberties
Since 2023, NHC has run a Russia sanctions project, which combines research and advocacy, in partnership with Corisk, a country risk analysis consultancy, and assisted by Wikborg Rein, a leading law firm in Norway. Corisk uses customs and trade data to mirror Russia’s trade. The data reveal which goods Russia imports and where sanctioned goods are routed. In other words, we can detect vulnerabilities in Russia’s war economy and holes in the sanction net.
The project aims to reduce the flow of sanctioned goods to Russia, or at least increase their import cost, especially those crucial to the military sector, by strengthening enforcement and raising awareness of the risk associated with evasion. Our advocacy efforts focus on four levels: Political institutions, media, enforcement bodies, and the business community. It is hard to estimate the precise impact, but the level of access and attention suggests that the effect has been substantial, i.e., the project has helped shape policy and laws.
In 2024, we held presentations/reports to authorities in Finland, Lithuania, Poland, Germany, several EU bodies, and delegations. We were asked to present as experts at events in the OSCE (in Vienna), G7+ (in Warsaw), and at an event organized in Brussels by Fertilizer Europe. We worked with council delegations and members of the European Parliament in the trilogue preceding the adoption in April of the EU Directive on the definition and penalties for violations of Union restrictive measures.
With regard to media, we worked with Aftenposten (Norway) on a major story about the Norwegian Oil Fund and violations of the Russia sanctions. We advocated for the Fund to adopt a stronger policy on sanctions and followed up the story with advocacy in the Norwegian Parliament. We contributed to and were cited in stories by the Financial Times and Bloomberg. Corisk was portrayed in a documentary by ARTE and used as an expert by Al Jazeera.
We worked with NRK and other media on investigations about sanction violations by Norwegian, Finnish, and Swedish companies. In November, Frankfurter Allgemeine Zeitung ran a story, based on our data and analysis, on Russia’s import of sanctioned European trucks, focusing on Daimler Truck. After the publication, we had several meetings in Berlin, including with the Bundesministerium für Wirtschaft und Klimatschütz (BMWK) staff and senior politicians in the Christian Democratic Union of Germany (CDU).
We collected data on-site during two fact-finding missions to Lithuania and Georgia, met with enforcement authorities in Poland, Lithuania, and Finland, and gathered evidence to file police complaints against companies in Norway and Germany that may have violated national sanctions laws.