A new report by Erlend Bjørtvedt, Maksym Steblivskyi, and Darya Kuzmina identifies goods, materials, and services that remain outside key EU sanctions restrictions despite their potential importance to Russia’s military-industrial complex.
The Sanctions Lab List: Non-Sanctioned Trade That Sustains Russia’s Military-Industrial Complex, published by Corisk and StateWatch, examines gaps in the current sanctions regime and identifies areas where European and Norwegian trade may continue to support Russian wartime production.
The analysis combines Russian customs data with insights from Ukrainian defence manufacturers to identify critical technologies, materials, and supply-chain dependencies that could warrant additional scrutiny or restrictions.
Russia Remains Dependent on Foreign Technology
Interviews with Ukrainian defence manufacturers indicate that Russia has made progress in localising production of components for unmanned aerial vehicles (UAVs). However, the report finds that Russia remains highly dependent on foreign supply chains for technologically demanding components, including batteries, rare-earth magnets, servo drives, optical systems, and electronics.
The researchers note that Russia has made particularly visible progress in satellite communications, while jam-resistant long-range communications, automated day/night target recognition, and next-generation battery technology could become increasingly important for battlefield advantage.
At the same time, many of the most critical components remain difficult for Russia to manufacture domestically, with China providing a significant share of imported technology.
Sanctions Gaps Allow Important Goods to Reach Russia
Despite successive rounds of sanctions, the report identifies several product categories that remain outside EU export restrictions even though they may contribute to Russia’s military-industrial capacity.
Among the goods highlighted are aluminium oxide, copper matte, unwrought zinc, industrial sewing machines, glass-fibre products, and machinery used for coating or impregnating textiles.
The scale of some of this trade is significant. According to Russian customs data analysed in the report, more than $420 million worth of aluminium oxide was exported directly from Europe to Russia in 2024. The material is essential for aluminium production and can ultimately enter supply chains serving Russian weapons manufacturers.
The report also identifies more than $159 million in European exports of copper matte to Russia in 2024, while other non-sanctioned goods examined in the study have links to Russian companies supplying sanctioned industrial and defence enterprises.
Maritime Services Remain Another Sanctions Gap
The report also examines European maritime services that continue to facilitate Russian trade.
While sanctions restrict services related to some Russian oil exports and prohibit Russian-registered vessels from accessing EU ports, other activities remain permitted. These include services connected to Russian LNG, metals, raw materials, fisheries, ship management, crew recruitment, and other maritime operations.
The authors argue that these services can support Russian export revenues and tax income while also creating wider security concerns for European countries.
The report pays particular attention to Norway, which continues to provide several maritime services to Russian fisheries and shipping that are no longer available elsewhere in Europe.
Closing Gaps in the Sanctions Regime
The findings demonstrate that assessing sanctions effectiveness requires looking beyond products already included on sanctions lists.
Goods that appear civilian or commercially ordinary can become important when they enter supply chains connected to Russia’s military-industrial complex. The report therefore recommends further sectoral sanctions on identified product categories and calls on European and Norwegian manufacturers to closely monitor sales of goods that remain legally exportable but may present elevated sanctions and end-use risks.
By identifying these gaps before they become more deeply embedded in Russian supply chains, policymakers can strengthen export controls and reduce Russia’s access to the materials, technologies, and services needed to sustain its war economy.
Read the full report: Sanctions Lab List: Non-Sanctioned Trade That Sustains Russia’s Military-Industrial Complex.
Explore Sanctions Compliance with TRACER
How effectively are countries implementing export restrictions against Russia? Explore the Trade Redirection and Circumvention Evaluation Ranking (TRACER), which assesses sanctions enforcement capacity and circumvention risks across 38 countries, combining evidence on legal frameworks, government enforcement, corporate compliance, structural constraints, and observed trade outcomes.
Explore the TRACER Compliance Index.
Further Research on Sanctions from KSE Institute
For further analysis of sanctions against Russia, explore research from the KSE Institute, whose Sanctions Expertise Hub examines the effectiveness of sanctions, export controls, Russia’s military-industrial complex, energy revenues, the shadow fleet, and the broader impact of restrictions on the Russian economy.
Explore KSE Institute research on sanctions against Russia.
Read the full report: Sanctions Lab List: Non-Sanctioned Trade That Sustains Russia’s Military-Industrial Complex.
