When the EU adds an intermediary company to its sanctions list in another package of restrictions, Russia replaces it with a new one — sometimes within weeks. This logic was described by Vladislav Vlasiuk, the presidential envoy of Ukraine on sanctions policy, in an interview with LIGA.net: as long as there is demand for re-export and the possibility to carry it out, new intermediaries will appear faster than they can be banned.
What's wrong with targeted sanctions
The classic scheme works like this: Russia orders a sanctioned product through a third country, a local intermediary company re-registers the cargo and ships it further. The EU identifies the scheme, adds the company to the list — and the scheme restarts with a new legal entity. Vlasiuk argues that this game with lists is a losing proposition by definition: targeted strikes against individual entities do not cut off the channel but merely force its participants to register new structures.
A more effective model is sectoral: banning not companies but categories of goods to a specific country if trade statistics indicate abnormal re-export.
The Kyrgyzstan case: how it works in practice
This is exactly the approach the EU applied in the 20th package of sanctions against Russia. According to EU data, Kyrgyzstan's imports of specialized electronics from the EU increased by more than 800% in 2022–2025, while re-exports of these same goods from Kyrgyzstan to Russia increased by approximately 1200%. Brussels banned supplies to the country of two categories of goods — CNC machines and radio equipment — without targeting individual players but cutting off the channel by product type.
«As long as there is demand for re-export and the possibility to carry it out, new intermediaries can appear quite quickly».
Vladislav Vlasiuk, presidential envoy of Ukraine on sanctions policy, in a conversation with LIGA.net
The result: approximately 50 Kyrgyz companies engaged in re-export closed after restrictions were introduced. Vlasiuk cites this case as proof that the sectoral approach destroys the scheme systematically rather than forcing it to migrate.
Hong Kong, machine tools, and the silent zone of risk
Kyrgyzstan is not the only point of vulnerability. According to LIGA.net, citing Vlasiuk's data, from January 2024 to February 2025 alone, sanctioned goods worth at least 47 million euros passed through Hong Kong to Russia — telecommunications equipment, signal generators, oscilloscopes, electronic components for communication, electronic warfare and navigation systems. Vlasiuk separately identifies the supply of CNC machines through Central Asia and the Caucasus as a zone requiring separate sanctions pressure.
Gap in domestic legislation
Alongside calls to the EU to strengthen sectoral restrictions, Vlasiuk identifies a problem within the country: Ukraine still lacks criminal liability for facilitating sanctions evasion. Presidential bill No. 12406 — submitted to the Verkhovna Rada in January 2025 — passed only its first reading in June with the support of 254 deputies. The document provides for a fine of 425,000 to 2.04 million hryvnia or imprisonment for 2–10 years for both intentional and negligent violation of sanctions. For comparison: the European Union obligated all member states to criminalize such violations in April 2024 — as a condition for approximation with the EU, Ukraine must do the same.
- Sectoral bans are more effective than targeted lists: they cut off the channel rather than forcing the scheme to relocate
- Hong Kong and Central Asia — active evasion routes with verified volumes
- Bill No. 12406 — stalled after first reading: a second vote has not been scheduled yet
- EU Directive 2024 requires criminalization of sanctions violations from all accession candidates
Why now
The EU's 20th sanctions package and the Kyrgyzstan case gave Ukraine a concrete argument: the sectoral approach yields measurable results. Meanwhile, EU Special Envoy on Sanctions David O'Sullivan continues diplomatic pressure on third countries but acknowledges: until the US and G7 synchronize restrictions, the effect of blocking individual routes remains partial. Against this backdrop, the delay in passing law No. 12406 looks like a signal to partners: Kyiv is demanding from others what it has not yet implemented itself.
If the Verkhovna Rada passes bill No. 12406 in its second reading by the end of the autumn session, it will remove one of the formal arguments that third countries use to justify their inaction. If not, the question of whether Ukraine's sanctions rhetoric is a tool of pressure or merely a diplomatic message will remain open.
