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Begin New Search Topic Sanctions Author Spencer Faragasso

1. New Information on Shenyang Machine Tool Company’s Illicit Sales to North Korea and Russia

Author:
David Albright and Spencer Faragasso
Publication Date:
01-2025
Content Type:
Special Report
Institution:
Institute for Security and International Studies (ISIS)
Abstract:
Several years ago, the Institute reported about the relatively large, multinational Chinese company Shenyang Machine Tools Company supplying sophisticated computer numerically controlled (CNC) machine tools, equipped with Western controlled software, to North Korea in violation of UN Security Council (UNSC) sanctions and a supplier country’s trade control laws that banned re-export of this software. New information details the disingenuous way in which the Chinese government investigated this case, indicating nonetheless inadvertently that North Korea received these machine tools, while also demonstrating China’s utter disregard for enforcing UNSC sanctions or its own or others’ export control laws. This case serves as another of the many cases highlighting China as a long-time irresponsible trading partner that responsible companies should avoid when sensitive dual-use goods are involved, lest they be complicit in outfitting North Korea’s, Iran’s, or Russia’s military programs. Today, responsible suppliers are inadvertently facilitating Russia’s prosecution of an illegal war against Ukraine. Given Shenyang Machine Tools Company’s recent exports of goods to Russia with Harmonized Shipments (HS) codes found on the Bureau of Industry and Security (BIS) Common High Priority List (CHPL), this company should be considered for sanctions.
Topic:
Sanctions, Trade, Illegal Trade, and Shenyang Machine Tool Company
Political Geography:
Russia, China, Europe, Asia, and North Korea

2. Action from Semiconductor Companies is Long Overdue

Author:
David Albright and Spencer Faragasso
Publication Date:
09-2024
Content Type:
Special Report
Institution:
Institute for Security and International Studies (ISIS)
Abstract:
The United States and its allies have struggled to stop the supply of controlled microelectronics to Russia, which then uses them in a variety of drones, missiles, and other weapon systems in its brutal war against Ukraine. While the United States and its allies can do more, it is time to turn far greater attention to the Western companies making these goods and demand far more from them. A recent companion study of trade data charting exports from China to Russia in a twenty-month period up to the end of 2023, conducted by one of us, showed that exports of the most critical microelectronics, electronic integrated circuits, amounted to $1.5 billion, steadily increasing throughout 2023, despite Western restrictions and pressure on China, which remains uncooperative, even hostile. 1 Electronic integrated circuits take on special significance, because Russia cannot make them, and there are limited manufacturers in the world, almost all in the United States and Europe. In a four-tier U.S. priority listing of banned electronic and other components and the means to make them, Tier 1 is exclusively composed of electronic integrated circuits. Aided importantly by China, Russia is countering the sanctions imposed by the United States and its allies. Without more countermeasures and enforcement, it would be unsurprising to find Russia continuing to acquire large quantities of restricted Western microelectronics needed for its war production.
Topic:
Sanctions, Weapons, Trade, Semiconductors, and Russia-Ukraine War
Political Geography:
Russia, Ukraine, and United States of America

3. Russian Company Elmak Procures “High Priority” Items for Russia’s War Efforts via China

Author:
David Albright and Spencer Faragasso
Publication Date:
06-2024
Content Type:
Special Report
Institution:
Institute for Security and International Studies (ISIS)
Abstract:
Russian weapons, including bombs, missiles, and drones, depend on crucial electronic components, such as field programmable gate arrays (FPGA) and microcontrollers, many of which cannot be made by Russia. In many cases, produced only by Western companies, these essential components are being sourced by Russian electronics importers and trading companies in large quantities from, foremost, China. The Russian trading company Elmak LLC, aka Kometa LLC, has imported over $5 million of Western electronic goods, almost entirely via China. Over 90 percent of the items fall under Tier 1 of the Bureau of Industry and Security and European Union List of Common High Priority Items banned for export to Russia and at heightened risk of being diverted to Russia illegally due to “their importance to Russia’s war efforts.” China’s lack of action to prevent these sales justifies NATO’s recent labeling China as a “decisive enabler of Russia’s war against Ukraine,” 1 adding weight to calls for the application of more sanctions against Chinese suppliers and enabling banks. But U.S. and other Western companies need to do more. They should not ship to China any electronics known to be used in weapons against Ukraine. U.S. companies should show greater due diligence on the final use and end users of their products and simplify supply chains to prevent unauthorized transfers of electronics with restricted Harmonized System (HS) codes. At the very least, companies should agree not to export the most important electronic items to China, which have been identified in Russian weapons downed in Ukraine. Otherwise, as the war continues, with more U.S and other Western manufacturers’ electronics found in Russian weapons in Ukraine after causing casualties and destruction, these manufacturers look increasingly insensitive and powerless against their own complicity in supporting Russia’s illegal war.
Topic:
Sanctions, Weapons, Trade, Imports, and Russia-Ukraine War
Political Geography:
Russia, China, Europe, and Ukraine

4. A Strategic Challenge: A Peddling Peril Index Analysis of Countries’ Restricted Russia Trade

Author:
David Albright, Sarah Burkhard, and Spencer Faragasso
Publication Date:
07-2023
Content Type:
Special Report
Institution:
Institute for Security and International Studies (ISIS)
Abstract:
National trade control systems and sanctions enforcement across the globe have been particularly challenged by Russia’s 2022 invasion of Ukraine, the unexpected types and number of goods to control, the need for rapid control of those items, and Russia’s determination to thwart others’ trade controls. The Russian situation demonstrates that even countries with strong strategic trade control systems have vulnerabilities. • In the aftermath of Russia’s invasion of Ukraine, the results of the Peddling Peril Index (PPI) for 2021/2022 provide a method to assess a total of 31 countries identified by their respective roles in the transshipment of restricted goods or the supply of dual-use goods used by the Russian military. • The purpose of this study is to identify patterns in these countries’ scores and lessons in finding ways of thwarting Russia’s success in violating sanctions and export controls.
Topic:
Sanctions, Exports, Trade, and Russia-Ukraine War
Political Geography:
Russia and Europe

5. Iranian Illicit Procurement Scheme to Acquire Controlled Spectrometry Systems Busted

Author:
Spencer Faragasso and Sarah Burkhard
Publication Date:
09-2021
Content Type:
Special Report
Institution:
Institute for Security and International Studies (ISIS)
Abstract:
On September 9, 2021, the German Federal Prosecutors Office issued an arrest warrant for a German-Iranian citizen, Alexander J., who is accused of illegally exporting a multitude of laboratory equipment, including four spectrometers, in three separate cases, exports that appear to have also violated the Joint Comprehensive Plan of Action (JCPOA).1 The total value of all the goods exported to Iran is 1.1 million euros. The defendant, Alexander J., is accused of violating the Foreign Trade Act (AWG) and Regulation (EU) No. 267/2012 of March 23, 2012, as amended in October 2015 in response to the establishment of a special Iranian procurement channel in the JCPOA, which places restrictive measures on certain Iranian entities and equipment for export (and related activities, such as brokering). In the first two cases, Alexander J. is alleged to have exported items to an Iranian national whose Iran-based companies were EU-sanctioned front companies procuring laboratory equipment for Iran’s nuclear and ballistic missile programs at the time. Alexander J. further supplied the sanctioned entity with two spectrometers listed in Annex II of this EU regulation, which lists items that are not on the EU dual-use control list (Regulation (EC) No 428/2009 of 5 May 2009) but that could contribute to sensitive activities, including enrichment-related activities, reprocessing or heavy-water-related activities.2 These items require a license on a case-by-case basis. In addition, Alexander J. violated the regulation by providing goods to an embargoed entity. In the third case, Alexander J. exported two listed spectrometers to a different, unspecified Iranian entity, also without the required license.
Topic:
Security, Nuclear Weapons, Treaties and Agreements, Sanctions, and Procurement
Political Geography:
Iran and Middle East