Fighting against sanctions circumvention

OLAF a leader in the fight against sanction circumvention

Following Russia's invasion of Ukraine, the EU adopted several sanction packages against Russia and its ally Belarus to target their economies and reduce the money they can spend on their unjust war against Ukraine.

From March 2022 to the end of 2023, the EU implemented 12 sanction packages against these two countries, which included import and export bans on a number of goods.

OLAF works in several ways to help enforce these sanctions, either by direct enquiries of potential breaches or by cooperating with partners in the EU and beyond to share knowledge and create a collaborative approach to defending the packages, and consequently, Ukraine itself.

OLAF monitors trade flows, performs analytical work to detect possible fraudulent circumvention of import/export sanctions, identifies suspicious operators and maps routes possibly used to try to evade trade restrictions.

OLAF also cooperates with the Member States and its international partners to produce intelligence packages and facilitate the real-time exchange of operational information in the conduct of investigations.

This allows OLAF to promptly inform national authorities of any suspicious situations, as national authorities have the power to enforce the sanctions and stop operators that try to circumvent them. Such suspicions can include unusual movements of goods or other suspicious behaviour such as price anomalies that can be an indication that the goods traded to or from a third country have in fact their final destination or origin in Russia.

In June 2023, OLAF hosted national authorities, non-governmental organisations and industry representatives from the EU and beyond, at its headquarters in Brussels to exchange intelligence and coordinate action on the enforcement of trade sanctions against Russia. The meeting brought together customs and law enforcement representatives from EU Member States, the USA, the UK, Canada as well as leading industries affected by the sanctions and NGOs. The meeting allowed participants to exchange intelligence and strategies to support the correct enforcement of the sanctions. During the operational session that was limited to enforcement authorities, OLAF and investigators and analysts from the national authorities shared intelligence and case studies were presented. In this meeting it was agreed that a Joint Sanctions Enforcement Operation (JSEO) would be set-up with the focus on dual-use goods such as integrated circuits and electronic components.

The JSEO started operating on 1 July 2023 and is coordinated by OLAF. During the JSEO, OLAF provides information and intelligence analysis reports to the Member States and cooperates closely with their external enforcement partners.

OLAF also participated in the G7 sub-working group on Export Control Enforcement that was created with the aim to bolster compliance and enforcement of the sanctions and deny Russia the benefits of G7 economies.

By bringing together authorities, actors and partners that have the power to enforce the sanctions, OLAF is making sure that there is a strong and concerted approach which will make sure that the sanctions are effective.

OLAF is also cooperating closely with the Ukrainian authorities on the topic.

OLAF further fulfils its obligations on supporting EU sanctions against Russia and Belarus by providing investigative intelligence know-how and by acting as a bridge between the various national and international authorities.

As an investigative office, with 25 years of experience fighting smugglers and customs fraud, OLAF has extensive experience in analysing trade flows and data to detect suspicious operators and dodgy movements of goods. OLAF can utilise these talents to support Member States in the fight against sanction circumvention.