From new restrictions to closing the old ones

By early 2023 the sanctions effort had changed character. The tenth package, adopted in February, added restrictions and tightened export controls. But the interesting work had moved elsewhere: to enforcement.

Restrictions do not enforce themselves. Goods route through third countries. Components with civilian uses are bought by intermediaries who have no obvious connection to anything. A chip made in one country, sold through a distributor in a second and re-exported from a third is genuinely difficult to trace.

What the enforcement effort involved

Sanctions envoys visiting third countries to explain the secondary risk to their banks and exporters. Trade statistics analysed for the tell-tale pattern of a small country suddenly importing twenty times its historic volume of a controlled component. Common lists of high-priority items shared between jurisdictions so exporters knew what to watch.

For a compliance officer this is familiar and unglamorous work — screening, documentation, end-user verification. It is also where a sanctions regime either functions or quietly stops functioning.