Despite successive EU measures since 2022, Russia continues to acquire critical machinery and dual-use components via re-exports through EAEU corridors, opaque corporate chains, and third-country routing. Fragmented national enforcement and restricted access to beneficial-ownership data have left systemic gaps that evasive networks exploit, sustaining flows that feed Russia’s military-industrial base.

This report documents firm-level evasion pathways and trade patterns and proposes an enforcement upgrade path: establish an EU centre of gravity for sanctions on an OFAC-like footing, consolidate beneficial-ownership transparency under AMLA, designate EAEU evasion hubs as high-risk, and embed sanctions/AML chapters in EU trade arrangements with monitoring mechanisms. The result is a coherent blueprint to turn sanctions from rules on paper into outcomes in practice.