Kyiv, Ukraine’s capital, is being deliberately pushed by Russia into a humanitarian crisis. Russian missile and drone strikes against energy infrastructure have left millions of civilians without heating, electricity, or running water. As temperatures drop to –20°C, entire neighbourhoods are plunged into cold and darkness.
Against this backdrop, the European Union continues to emphasise a targeted sanctions approach toward Russia. Existing measures focus on specific companies, individuals, and narrowly defined categories of sensitive goods, while also allowing for long transitional periods. European Union sanctions targeting Russia’s military-industrial complex still influence Russia.
For example, in 2025 the Economic Security Council of Ukraine with partners analysed Russia’s dependence on imported chromium for artillery production. Following an advocacy campaign, EU restrictions temporarily shut down Russian plants in early 2025 after they failed to adapt to disrupted supply chains. But sanctions constantly require responses to the most critical points of circumvention. At present, the most critical point lies in combating sanctions evasion through third countries.
The instrument of banning the supply of sensitive goods to specific third countries remains one of the few genuinely impactful options still available to the EU. This mechanism was formally introduced back in the 11th sanctions package, yet to this day, both the list of goods and the list of countries remain empty.
President von der Leyen announced that in the 20th sanctions package the EU will finally use this mechanism. However, the ban will apply only to the export of the CNC machines to Kyrgyzstan. And what is needed now is a strong, visible case that sends a clear signal to all intermediaries that the EU is prepared to impose real costs for enabling Russia’s war economy.
Goods: use what already exists
When it comes to the list of goods, the solution is relatively straightforward. The Common High Priority Items List (CHPL) already exists. This list was developed by the G7 specifically to guide diplomatic engagement with third countries on export controls. The EU has repeatedly urged third states not to re-export these items to Russia. However, the effectiveness of such diplomacy has always depended on whether the EU had any real "sticks" to enforce compliance.
Restricting exports of at least CHPL-listed goods to countries that systematically re-export them to Russia would be a logical and long-overdue application of this framework. By 2026, it is clear that the CHPL in its current form no longer works as intended and requires both updating and enforcement. Without consequences, lists and dialogues remain symbolic gestures rather than instruments
of pressure.
Countries: the political constraint problem
The more difficult issue is the selection of countries. If one looks at the main third-country hubs involved in supplying sanctioned goods to Russia, China and Türkiye inevitably emerge as key players, not Kyrgyzstan. The supplies of Western CNC machines to Russia through these countries even attracted the interest of the European prosecutors in specific investigations. In 2025, the German machine tool manufacturer Spinner was publicly accused of sending over 20 high‑precision machine tools to Russia through Türkiye, China and Uzbekistan.
Hong Kong is another important country. The EU maintains separate agreements with the Hong Kong Special Administrative Region on customs cooperation and mutual administrative assistance. In 2023 the EU was Hong Kong's third largest trading partner 5 .
Between January 2024 and February 2025, Russia imported CHPL-listed goods through Hong Kong that had originally been manufactured in several EU member states and European partners: USD 9.4 million from the Czech Republic, USD 2.7 million from Germany, USD 657,000 from France, USD 378,000 from Switzerland, USD 235,000 from Finland, USD 166,000 from Latvia, and USD 124,000 from Italy. This is not an abstract risk but a documented channel through which European- made sensitive goods continue to reach Russia’s war economy.
Georgia represents another critical node in sanctions circumvention networks, serving as a logistical, financial, and re-export hub for Russian trade. According to official statistics, in 2023 and 2024, Georgia exported dual-use items worth $10.7 million to Russia, Armenia, Azerbaijan, and Central Asia.
These are only some of the routes through which goods continue to reach Russia and many other countries may also be involved in sanctions-evasion schemes, either as transit hubs, re-export platforms, or jurisdictions that lack effective export controls and enforcement mechanisms. And Kyrgyzstan is definitely not the biggest problem here.
Sanctions as a tool, not a symbol
Sanctions inevitably harm economic development. In moments like these, policymakers face a fundamental choice: money or security.
This requires a conceptual shift. Sanctions should be treated as a strategic instrument designed to achieve a concrete objective. If that objective is not being met, then more resources must be invested, and real trade-offs must be accepted.
Without a willingness to incur economic and political costs, the sanctions policy will remain performative, and Russia will continue to exploit the gaps.
