Sanctioned Keep Reaching Russia as Europe Struggles to Close the Gaps

The EU’s 20th sanctions package closes a critical loophole on military rubber supplies, but investigative findings and enforcement data show that circumvention networks remain far ahead of the rules designed to stop them.

Last November, Politico published findings from the Economic Security Council of Ukraine (ESCU) revealing that nearly 2,000 tonnes of natural rubber worth $5.1 million had been exported from the EU to Russia in 2024. The material is not incidental to Russia’s war effort: rubber is an indispensable component for high-load aviation tyres, with Russian bombers reportedly cycling through sets every ten days due to the intensity of operations. One of the biggest suppliers identified was a Latvian company that shipped more than $2.2 million worth of natural rubber to Russian entities, including the defence ministry.

The investigation triggered a direct policy response. Natural rubber was included in the EU’s 20th sanctions package adopted on April 23, 2026. The package expanded the existing export ban to include rubber and articles made of vulcanised rubber worth over €360 million and introduced further import restrictions on rubber products worth over €570 million.

A New Tool, Used for the First Time

Beyond the rubber ban, the 20th package marked a procedural milestone. The EU activated its anti-circumvention tool for the first time, prohibiting exports of computer numerical control machines and certain telecommunications equipment to Kyrgyzstan to prevent their onwards transfer to Russia. Kyrgyzstan is the first country ever designated under this instrument, which had existed on paper since the EU’s 11th sanctions package in 2023.

The logic is straightforward: extend sanctions pressure beyond Russia to the intermediaries enabling circumvention. But investigators warn the effect will be limited. As ESCU’s Director for Analytics Olena Yurchenko told Politico, “Direct exports from the EU have been virtually reduced to zero, but the response to intermediaries in third countries is still not decisive enough.”

Denial, Deflection, and Occasional Cooperation

The gap between policy and reality becomes most visible when investigators confront the companies whose goods are found in Russia. Research documented sanctioned equipment from at least 30 EU and G7 brands at Moscow’s Metalloobrabotka-2025 trade fair, including firms that had publicly announced their exit from the Russian market. German manufacturers Mahr and Spinner, whose equipment appeared at the exhibition alongside supporting customs records, called the findings disinformation. “Neither the company itself nor third parties supply products to Russia,” Spinner stated, despite audiovisual evidence, declarations and intermediary identification codes.

French tyre giant Michelin, which formally exited Russia in March 2022, has faced repeated documentation of its aviation tyres reaching Russian entities. The Guardian reported in September 2024, citing Ukraine’s National Agency on Corruption Prevention, that Russia imported aircraft tyres worth $30 million from Western manufacturers that year, with Michelin accounting for the majority. When the Guardian returned to the story in late 2025, citing ESCU research, Michelin’s response was notable: the company simultaneously disputed the investigators’ figures while citing them as proof of its own compliance system’s effectiveness. “Our adapted compliance programme has significantly reduced instances of circumvention, as evidenced by your latest data,” a Michelin spokesperson said, adding that there was “no guarantee that the tyres mentioned are actually Michelin Group products”. The figures being disputed: 2,687 tyres worth over $7 million were shipped to Russia between October 2024 and March 2025 alone.

Belgian company Campine NV, the world’s largest antimony oxide producer, offers a contrasting model. After reviewing an ESCU report in August 2025, the company conducted an internal audit, confirmed contacts with Russian intermediaries and committed to strengthening its control systems. It is a rare example of genuine cooperation rather than blanket denial, though it does not erase the fact that the deliveries took place and strengthened Russia’s capacity to produce new weapons.

Convictions and Fines Across Europe

Enforcement cases are becoming more frequent and more serious across the EU, even if they remain uneven. According to a press release by German Customs (Zoll), the Marburg Regional Court on July 8, 2025, sentenced a businessman to five years in prison for exporting 71 luxury vehicles to Russia in breach of EU sanctions, with approximately €5 million in criminal proceeds confiscated. In a separate case in March 2026, the Würzburg District Court sentenced another individual to six years in prison for supplying 111 executive-class cars to Russia through a network of shell companies, with around €20 million confiscated. Customers for the vehicles included Russian state agencies and state-owned corporations.

In Estonia, the courts convicted Marine Technics Baltia OÜ and its board member Daniil Haitin on November 5, 2025, for exporting gas generators, propulsion systems, thermal cameras and other equipment to Russian military end-users, including Kalashnikov Concern and the Russian Ministry of Defence. False end-user certificates had been prepared showing Turkey as the purported destination. Haitin received a sentence of four years and eleven months; the company was ordered to pay €160,000 in fines. A separate conviction, also in Estonia in 2025, targeted freight forwarder Alus Grupp OÜ for transporting dual-use resonance testing machines used in aviation and aerospace to Russian customers via Kazakhstan and the UAE.

In Poland, the national tax administration (KAS) imposed a PLN 20 million (€4.7 million) fine on a company that exported luxury cars to Russia in breach of EU sanctions, as reported by Global Sanctions citing the Polish authorities. In Denmark, a subsidiary of Swedish manufacturer Alfa Laval pleaded guilty to exporting centrifuge parts to a Russian sister company and was fined roughly €13,400 — a figure widely noted as disproportionately low relative to the gravity of the violation.

The American Model

The contrast with US enforcement remains stark. When ESCU analysts flagged a potential sanctions violation involving American machine tool manufacturer Haas Automation in 2023, the US Bureau of Industry and Security and the Treasury’s Office of Foreign Assets Control imposed a combined penalty exceeding $2.5 million in January 2025. The mechanisms behind that outcome, OFAC and BIS, have no direct EU equivalent. American companies face predictable and severe consequences, which concentrates compliance efforts. The result is measurable: US-origin components are appearing less frequently in Russian military equipment.

The Architecture Problem

The deeper issue is structural. Unlike the United States, the EU operates across 27 separate enforcement jurisdictions, each responsible for compliance within its own borders and each with different resources, political will, and legal traditions. Russia exploits this mosaic systematically, routing goods through whichever member state offers the weakest oversight.

The 20th sanctions package takes steps to close some gaps. New rules now subject non-financial intermediaries that enable international payments through netting and set-off arrangements to transaction bans for the first time. The package adds 120 new listings, the largest number in two years. A new EU Sanctions Directive, which member states were required to transpose by May 2025, harmonises the enforcement framework across the bloc and raises maximum penalties to fines of 5% or more of global annual turnover for serious violations, with prison terms of five years or more for individuals.

Whether this translates into effective pressure depends on implementation and national political will. The sanctions are becoming sharper. The question is whether enforcement will keep pace with the networks built to evade them.