Russia and Belarus may attempt to evade U.S. export control. For that purpose, they can use so-called transit countries, according to the Financial Crimes Enforcement Network (FinCEN) and the U.S. Department of Commerce’s Bureau of Industry and Security (BIS).
The BIS has identified countries that facilitate the transit of sanctioned goods as transshipment points. Among them are Armenia, Brazil, China, Georgia, India, Israel, Kazakhstan, Kyrgyzstan, Mexico, Nicaragua, Serbia, Singapore, South Africa, Taiwan, Tajikistan, Turkey, the UAE and Uzbekistan.
«In some instances, controlled U.S. items may be legally exported to these and other jurisdictions as inputs for the production of other finished goods. However, further export to Russia or Belarus of those finished products and goods, potentially through additional transshipment points, may be prohibited,» the agencies said in the joint statement.
As a result, the US government has urged financial institutions to be vigilant against efforts by individuals or entities to evade BIS export controls implemented in connection with Russia’s further invasion of Ukraine.
In turn, Kazakhstan is trying to monitor sanctioned goods that may be exported or imported via the country. «Despite the growing exports of specific goods into the Russian Federation, we haven’t seen any facts of sanctioned goods re-export through the Republic of Kazakhstan,» the country’s State Revenue Committee reported.