The Russian war machine, though hampered by Ukrainian resistance, logistical issues, and Western sanctions, continues to attack civilians and civilian infrastructure.
Much of the Russian ammunition, drones, and other military equipment are made using imported components, which Russia continues to acquire by utilising different sanction circumvention schemes.
A coalition of leading experts and civil society organizations — including Royal United Services Institute (RUSI), Open Society Justice Initiative (OSJI), NAKO, and Heartland Initiative — has released guidance on concrete steps to be taken by businesses to cut Russian military end-users out of their supply chains.
Titled ‘Managing Risks Created by Russia’s Invasion of Ukraine: Enhanced Due Diligence and Advanced Know-Your-Customer Policies,’ the document is designed to help companies scrutinise their trade operations and ensure their goods do not end up in the hands of the Russian military.
Businesses have a moral and legal responsibility to ensure their actions — or inactions — do not contribute to human rights abuses and violations of international law. There are serious legal, reputational, and regulatory risks for businesses whose components end up in Russian weapons used in violations of international law.
This guidance offers a comprehensive set of red flags and tools for companies to use to identify suspicious front companies that might be conduits for the flow of sensitive goods to Russia. It provides concrete steps for businesses to take to enhance their due diligence processes, and details case studies of sanctions circumvention schemes used by Russia to procure sensitive technology.
Businesses must act now to implement these recommendations and cut Russia’s access to the critical components it needs to sustain its war effort. Governments must issue comprehensive due diligence guidelines and update current regulations that businesses must follow to curtail Russia’s access to sensitive technology and undermine its ability to wage its illegal war of aggression against Ukraine.