Dealing with Third-Country Involvement in Sanctions Evasion

Dealing with Third-Country Involvement in Sanctions Evasion

A major challenge to enforcing sanctions effectively is the involvement of third countries that are not subject to sanctions and have no obligation to implement them. In the interconnected global economy, trade and financial transactions can pass through these nations, facilitating the circumvention of sanctions.

Since the broad sanctions imposed on Russia in 2022, the EU, U.S., and UK have stepped up their efforts to tackle sanctions evasion and avoidance (SEA) involving these jurisdictions.

"A key challenge to the effectiveness of sanctions lies in the role of third countries that are neither subject to sanctions nor obliged to enforce them."

Summary: Third-country jurisdictions play a crucial role in sanctions evasion, prompting intensified measures by the EU, U.S., and UK to strengthen enforcement against these loopholes.

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Clingendael Clingendael — 2025-11-07