Issue 02 . Jul 2024
In the aftermath of Russia’s invasion of Ukraine, the EU, US, Japan, the UK and others collectively applied trade embargoes to specific “high-priority common items,” “critical items” and “battlefield items” to stop the proliferation of Western-made components ending up in Russian manufactured military items. The Financial Crime Enforcement Network (FINCEN) under the US Treasury Department and the Bureau of Industry and Security (BIS) under the US Commerce Department, as well as the EU, also specified high-risk transshipment areas known to be facilitating the reexport of Western-made components to Russia, mentioning Armenia, Brazil, Georgia, India, Israel, Kazakhstan, Kyrgyzstan, Mexico, Nicaragua, Serbia, South Africa, Taiwan, Tajikistan, United Arab Emirates and Uzbekistan. In the context of the above, this paper will provide an analysis on the trade flow of certain US components into those transshipment points in the last two years to assess whether Russia is profiteering from importing reexported US components.
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