Restricted goods and technologies have been seen to be exported via third countries to Russia/ Russian end users. Such exports undermine and circumvent the effectiveness of sanctions imposed by the EU and others. To combat this, the main strategy of the EU and G7 countries has been to engage in diplomatic dialogue with relevant third countries to get them to cooperate. This remains the main strategy, and the latest EU sanctions package emphasizes the need to strengthen such cooperation, and to provide third countries with relevant technical assistance in this respect.
However, the 11th sanctions package states that - where efforts to achieve bilateral or multilateral cooperation fails - further targeted and proportionate actions should be taken to deprive Russia of the resources allowing it to pursue the war against Ukraine. Such actions include listing persons and entities under the blocking list or the list of entities to which export and sale of dual-use and advanced technology items are prohibited, and the latest package includes the listing of entities in Armenia, China, Iran, Syria, United Arab Emirates, and Uzbekistan. An earlier list of Chinese entities proposed for such barring has been the topic of much discussion, considering the EU's complex relationship with China, and Russian dependency on Chinese support. According to several media reports, the EU originally planned to list eight Chinese companies but ended up listing only three following diplomatic talks with China.
Furthermore, the 11th sanctions package also includes a new anti-circumvention tool whereby the EU may prohibit the sale, supply, transfer or export of dual-use goods and technology, or goods and technology that might contribute to the enhancement of Russia’s military, technological or industrial capacities or to the development of Russia’s defence and security sector to countries that are associated with a high risk of being used for circumvention, such as Armenia, Kazakhstan, China, Turkey and others. This tool is however reserved to scenarios where other actions prove inadequate, and the EU refers to them as "exceptional, last-resort measures". As per now, this is simply a mechanism with an empty annex, but it does provide the EU with an effective means to swiftly impose restrictions on the assumed circumvention vehicle countries if they continue to "systematically and persistently" fail to prevent export to Russia/Russian persons of goods from the EU even after outreach and assistance has been offered by the EU to the country in question.