Annual Report 2025

The sanctions against Russia are intended to stop an illegal war. In its third year, NHC’s groundbreaking sanctions project continues to deliver essential results.

The sanctions against Russia are perhaps the clearest example of a sanction regime in support of international law since Norway, and several other states, imposed sanctions on the apartheid regime in South Africa in the 1980s. They also illustrate how sanctions have become a human rights instrument, a development driven by the so-called Magnitsky campaign, in which the Norwegian Helsinki Committee has participated since 2010.

The sanctions against Russia also have an impact—they weaken the Russian war economy and save Ukrainian lives.

The Norwegian Helsinki Committee’s sanctions project is based on cooperation with the Norwegian private analytics company Corisk. Wikborg Rein, a leading Norwegian law firm in international sanctions, supports us. Based on analyses of trade and customs data, we can see how export controls are circumvented, allowing goods from Western companies to reach Russia. We can track the routes the goods travel. We can also see that the volume of critical goods reaching Russia is decreasing, while prices have risen.

The data provides insight into what works and what does not in the sanctions against Russia. We have shared this knowledge with political decision-makers in the EU and several European states. We have also collaborated with media in many countries, including Georgia, Norway, Sweden, and Germany. Our investigations showing that European trucks and truck parts were ending up in Russia in violation of sanctions made news stories in the Frankfurter Allgemeine Zeitung and the Norwegian Broadcasting Corporation, NRK.

In April, NHC/Corisk, as one of three external presenters, was invited by the Polish presidency to a closed meeting for the EU’s RELEX advisors and representatives from the 27 capitals—the officials who design EU sanctions. In May, Poland invited us back to Warsaw to present on the status of sanctions circumvention in G7+, the alliance of the seven largest Western economies, Ukraine, and selected democratic states (including Norway and South Korea).

The main focus of our advocacy work has taken place in Brussels, where EU sanctions packages are developed and adopted. In June, the Helsinki Committee was invited by the Ukrainian and Norwegian embassies in Brussels to present on sanctions circumvention at the European Parliament. In December, the Helsinki Committee, together with the Norwegian environmental organisation, Bellona, and Truth Hounds from Ukraine, participated in a closed meeting at the German EU embassy to discuss the next steps in sanctions against Russian companies.

It can be difficult to assess the impact of advocacy. Based on our access to decision-makers and leading media, we believe it has been significant: our work has likely helped shape sanctions packages, policies, and the enforcement of sanctions laws in Europe. Based on our own and NRK’s investigations, we reported the Norwegian company Kongsberg Automotive to the police in February 2025 for violating due diligence provisions in sanctions legislation. This was the first time we filed a police report against a Norwegian company. The Norwegian Police Security Service (PST) is currently investigating the case.

Despite the impact, it has been difficult to secure funding for the project. Unfortunately, we have not been able to follow up on all the requests and inquiries we receive from businesses, media, and states. We particularly hope that the business sector will support a project that, fundamentally, is about creating a level playing field for businesses, for European and Norwegian companies. Violating sanctions should not be profitable for the cynical few, while most companies comply with the sanctions, and some pay a price for doing so.