In a daring collaboration with Spanish authorities, OLAF has uncovered a network circumventing EU sanctions on Russia. Arrests were made, and 13 tons of chemicals seized. Discover OLAF's Crackdown on Russian Sanctions Evasion: Spain's Operation Probirka
What Questions I Will Answer in this blog
How did OLAF assist in enforcing EU sanctions against Russia?
What role do export controls and due diligence play in preventing illicit trade?
How can professionals ensure compliance in this increasingly challenging environment?
Introduction
Since Russia's invasion of Ukraine, the European Union has imposed stringent sanctions to limit the flow of goods that could support the Russian military. Recent events highlight how crucial export control measures are in protecting the integrity of these sanctions. Spain’s Operation “Probirka,” supported by OLAF, has shed light on the illicit trade of restricted chemicals, reinforcing the importance of rigorous compliance.
"Sanctions enforcement is not just a legal obligation but a fundamental step towards maintaining international security. Compliance begins with due diligence." — Arne Mielken, Managing Director, Customs Manager Ltd
Abbreviations I Use in this Blog
To make this complex topic easier to follow, I’ll define some key abbreviations used throughout the blog:
OLAF: European Anti-Fraud Office
EU: European Union
ICP: Internal Compliance Programme
AML: Anti-Money Laundering
FTO: Free Trade Organisation
How did OLAF assist in enforcing EU sanctions against Russia?
OLAF’s collaboration with Spanish authorities was pivotal in breaking up a smuggling network intent on evading sanctions. By using advanced data analytics and intelligence-sharing, OLAF helped to identify companies exporting restricted chemicals to Russia via Kyrgyzstan.
Their efforts led to the arrest of four individuals and the seizure of 13,000 kilograms of chemical compounds at the Port of Barcelona. These compounds, which could potentially support Russia's military capabilities, were being illicitly routed through shell companies in Armenia and Kyrgyzstan. This breakthrough proves once again that enforcement is just as important as the imposition of sanctions.
see Press Release
What role do export controls and due diligence play in preventing illicit trade?
In my role as an export control consultant, I can’t stress enough how due diligence underpins compliance with export controls and sanctions. Had the companies involved in Operation Probirka implemented robust Internal Compliance Programmes (ICPs), this violation might have been avoided. ICPs help businesses identify red flags and ensure they adhere to sanctions regimes. OLAF’s operation also demonstrated the value of professionalism and accountability. Exporters must be vigilant about conducting detailed due diligence, especially in high-risk areas. Even seemingly innocuous products like chemicals can be dual-use items, meaning they have both civilian and military applications.
Do you have adequate procedures in place to avoid becoming part of an illegal supply chain? If not, this could put your business at high risk of violating sanctions and incurring penalties.
How can professionals ensure compliance in this increasingly challenging environment?
With the rise of global sanctions regimes, maintaining compliance is more complex than ever. Implementing a strong Internal Compliance Programme (ICP) is essential. This includes:
Thoroughly vetting your customers, especially those in high-risk regions.
Mapping out the supply chain to detect unusual trade routes or red-flag jurisdictions (such as intermediaries in Armenia or Kyrgyzstan).
Regularly update your due diligence checks to ensure they align with current sanctions.
For many businesses, navigating these complexities can be overwhelming. That’s why consultants like me offer tailored guidance and training to help businesses stay compliant.
A Client Success Story
Recently, I worked with GlobalChem Ltd, whose Export Control Manager, Emma Jones, was struggling to navigate the increasingly complex web of sanctions affecting their chemical exports. Emma was worried that some of their goods could be routed through risky regions without proper oversight, exposing the company to sanctions violations.
Through my expert consultation, we restructured their Internal Compliance Programme (ICP), conducted in-depth due diligence on all trade partners, and established rigorous checks on trade routes. With these measures in place, Emma was able to confidently continue her operations while ensuring full compliance.
Could your business benefit from a similar review of your compliance procedures?
Fancy a call?
I provide comprehensive support for sanctions compliance and export controls. I would love to discuss your challenges and how you can enhance your compliance procedures. Book your free expert call here. I offer public, in-house, and on-demand training tailored for professionals, including exporters, importers, and their partners. To learn more, visit www.customsmanager.org.
Arne’s Takeaway
Operation Probirka serves as a stark reminder that sanctions enforcement is not just about imposing regulations—it’s about active due diligence, vigilant monitoring, and, most importantly, taking responsibility as a professional in the field. Whether you are an import/export specialist, a sanctions consultant, or a customs agent, your role in this landscape is critical.
Expert Recommendations
Implement a thorough Internal Compliance Programme (ICP) to mitigate risks.
Conduct ongoing due diligence on clients and suppliers, especially in high-risk areas.
Stay updated on sanctions lists and adjust your compliance procedures accordingly.
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