Turkish Intermediary Established to Supply Flagged HS Codes Products to Russia | Kharon The Kharon Brief

Turkish Intermediary Established to Supply Flagged HS Codes Products to Russia

Kharon via Midjourney

By Kharon Staff

November 7, 2023

A Türkiye-based trading company has served as an intermediary for receiving and shipping restricted products that fall under controlled Harmonized System (HS) codes to a Russian company despite export control restrictions that were imposed on Russia following the invasion of Ukraine in early 2022.

The company, Evol Group TR Yazilim Limited Sirketi, was established in May 2022 by a Russian businessman, Mikhail Nikolaev, who also owns and manages the Russian company importing the controlled goods.

Kharon found that Evol Group has been receiving shipments of those restricted items from a French and a Latvian company since early 2023. The Turkish front company appears to then send those products to the Russian company known as PTK Apriori.

Kharon’s findings come as Russia continues to find ways to evade sanctions and export control restrictions, prompting U.S. and EU authorities to step up their enforcement actions.

Last week, the U.S. Department of the Treasury announced sanctions against 130 individuals and entities, including foreign intermediaries in Türkiye, China and the United Arab Emirates, that have helped Russia circumvent export control restrictions by providing them with technology and equipment that it likely uses in its war against Ukraine. 

“Today’s actions demonstrate our further resolve in continuing to disrupt every link of Russian military supply chain, and target outside actors who would seek to support Russia’s war effort,” said Secretary of the Treasury Janet Yellen in a statement. 

In June, the EU warned that the Russian government and sanctioned persons are “going out of their way” to evade sanctions and get dual-use technology through intermediaries.

Following those warnings, the U.S. Department of the Treasury in July sanctioned nearly a dozen foreign exporters that transferred advanced electronics flagged as high-risk of evasion to Russia.

In June, the EU, U.S., U.K. and Japan issued a notice identifying dozens of HS codes that pose “a heightened risk of being diverted illegally to Russia because of their importance to Russia’s war efforts.”

The U.S. Bureau of Industry and Security (BIS) and the Financial Crimes Enforcement Network (FinCEN) issued a similar joint alert in May urging financial institutions to be vigilant of Russia’s attempts to circumvent export control and acquire dual-use goods to use in its war against Russia. 

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