Ursula Riimaa, Deputy Director General of the Tax and Customs Board (ETCB) in the field of customs, explained that while trade with third countries has decreased significantly, imports and exports of certain goods have increased. “On one hand, this is due to legitimate trade – companies that fulfill their due diligence obligations have adapted to the changed geopolitical situation and have found new markets and supply chains. On the other hand, we also see increases in certain product categories that may indicate attempts to circumvent sanctions,” Riimaa said.
According to Riimaa, the ETCB’s primary objective since the start of the war has been to prevent sanctioned goods from reaching Russia. “Although most goods are subject to an export ban to Russia, the transit of many sanctioned goods through Russia is still permitted. Within the powers granted to us, we can intervene and, in cases of justified suspicion that the goods will end up in Russia, prevent their departure from Europe.” Riimaa emphasized.
Preventing the evasion of sanctions has become the most important focus in customs work. According to Riimaa, the Tax and Customs Board has implemented several targeted measures to achieve this goal. “We conduct thorough checks of goods and transport documents, assess risks across the entire supply and transport chain, and evaluate the logic of the chosen routes. Both the increasingly stringent sanctions and customs measures have already shown their impact in foreign trade statistics, but we see that the current sanctions regime could and should still be further strengthened,” Riimaa emphasized.
Since 2023, trade with Central Asian countries has been in a continuous decline, primarily reflected in a decrease in exports. From 2023, exports of goods have fallen by nearly 30 percent. Import volumes from Central Asian countries have remained stable, with the main decreases occurring in vehicle parts, timber and wood products, metal products, and other goods where the ETCB has suspected attempts to circumvent sanctions. Statistics also confirm that Central Asian countries have not been able to compensate for the volume of goods previously imported from Russia during the war – the difference between pre-war imports from Russia and wartime imports from Central Asian countries is sevenfold, amounting to approximately 3 billion euros.
At the same time, over the three-year period, export volumes have increased the most in the categories of cocoa products, vehicles and their parts, fish products, copper products, and plastic products. “For some goods – such as food products – no sanctions have been imposed, and the growth in these categories is understandable and does not indicate a violation of sanctions. However, in the case of sanctioned goods, where there may be doubts about the declared destination and the goods could actually end up in Russia, we, as a rule-of-law authority, cannot restrict trade based solely on assumptions. Additional measures are needed to provide us with a solid legal basis for detaining goods or preventing their trade,” Riimaa noted.
The ETCB has made several proposals to strengthen the effectiveness of sanctions. Among these is a proposal to ban the use of Russia as a transit country. Proposals have also been made to implement sanctions based on specific product categories and to eliminate temporary exemptions. “Such measures would further reduce the risk of sanctions evasion at the eastern border and help prevent temporary anomalies in trade,” Riimaa emphasized.
The analysis covered the following countries: Kazakhstan, Uzbekistan, Kyrgyzstan, Tajikistan, Azerbaijan, Turkmenistan, Georgia, and Armenia.
