Despite the imposition of an unprecedented set of sanctions against Vladimir Putin’s regime in the wake of its unlawful invasion of Ukraine, the Russian Federation has been able to find ways around these restrictive measures. Western technology continues to flow to the Russian market, including the dual-use goods that are being found in missiles used to strike Ukrainian cities and kill Ukrainians. With the help of a fleet of “shadow tankers”, as well as States and private parties willing to exploit the existing gaps for their economic gain, the Russian Federation has been able to avoid the effects of the oil price cap, with the price of the Russian crude oil remaining well over the cap of US$60 per barrel. Amid the catastrophic shortage of military equipment and ammunition in Ukraine, every cent gained by Russia in violation of sanctions contributes to the suffering of the Ukrainian nation.
Given the ineffectiveness and compartmentalisation of domestic procedures intended to supervise the proper implementation of restrictive measures, an international supervision mechanism is called for. Its main objective should be the identification of emerging forms of violations of sanctions, to propose remedial measures. The proposed mechanism should also identify entities, be it States or private parties, that take an active role in helping the Russian regime to evade sanctions.
It is necessary to resolutely counter the circumvention or attempts to evade sanctions. As stated in Resolution 2540 (2024), the Parliamentary Assembly should support the creation of a Register of entities, as well as natural or legal persons, that assist the Russian State, in circumventing sanctions. The list of entities, as well as natural or legal persons should be exposed in a public list. Appropriate restrictive measures should be imposed on them to deter such practices.