Illuminating the Role of Third-Country Jurisdictions in Sanctions Evasion and Avoidance (SEA)

Sanctions are an important tool for exerting influence internationally yet understanding of the impact of sanctions evasion or avoidance (SEA) and third-country involvement remains limited. In this study, third countries are defined as distinct from ‘senders’ and ‘targets’ of sanctions regimes and aims to shed light on their role in SEA. The report examines thirteen third countries (Armenia, Cyprus, Czechia, Georgia, Indonesia, Kazakhstan, Malta, Saudi Arabia, Serbia, South Africa, Spain, Türkiye and the UAE), involved in SEA relating to sanctions imposed on Russia since the Ukraine invasion. It draws from literature, data analysis of media reports, blogs, forums and other open-source information as well as trade and shipping data, spanning from February 2022 to February 2023.