Sanctions enforcement requires closer cooperation between authorities and companies
Researchers, policymakers, companies, and public authorities gathered in Stockholm on June 9 to discuss how sanctions can be enforced more effectively. The conference focused on export controls, sanctions circumvention, and the growing importance of cooperation across sectors and borders.
Researchers, policymakers, companies, and public authorities gathered in Stockholm on June 9 to discuss one of the most pressing challenges facing sanctions policy today: how to close the gap between sanctions on paper and sanctions in practice.
Organized by the Stockholm Institute of Transition Economics (SITE) and the Swedish Ministry for Foreign Affairs, the conference Sanctions Compliance and Enforcement: Strengthening Cooperation between Companies and Authorities focused on export controls, sanctions circumvention, and the growing need for cooperation across sectors and borders.
The point of departure was a sobering one. Four years into the sanctions regime against Russia, Western-made components — some with production dates as recent as 2025 — are still being recovered from Russian missile debris in Ukraine.
Why sanctions compliance matters
Opening the conference, Anna Ekstedt, Sanctions Coordinator at the Swedish Ministry for Foreign Affairs, together with EU Sanctions Envoy David O'Sullivan and Serhiy Polovynko of the Embassy of Ukraine in Sweden, emphasized that effective sanctions implementation is a shared responsibility of governments and the private sector.
Torbjörn Becker, Director of SITE, presented evidence on the macroeconomic impact of sanctions on Russia, showing how the war economy masks growing structural weaknesses, and discussing policy options that could both ease compliance and strengthen the effectiveness of sanctions.
Vladyslav Vlasiuk, Presidential Commissioner for Sanctions Policy of Ukraine, outlined areas where sanctions are having an impact on the Russian economy, including a widening budget deficit and falling oil and gas revenues. At the same time, he identified key areas where pressure should be increased, including cryptocurrency payments, technology flows to Russia's defense industry, and the shadow fleet that continues to support Russian energy exports.
How sanctions are being circumvented
A central theme throughout the day was the challenge of sanctions circumvention.
Pavlo Shkurenko, Compliance and Sanctions Advisor at KSE Institute, presented evidence showing that components from sanctions-coalition companies are still routinely found in Russian weapons. He mapped the main circumvention channels that allow Russia to access critical technologies, including substitution through non-coalition suppliers, transshipment through intermediary countries, and offshore production by subsidiaries of Western companies, and laid out concrete due-diligence practices, red flags, and enforcement cases that companies can learn from.
Reza Afshar OBE, Executive Director of Independent Diplomat, and Emma Winberg, Founder and CEO of the Centre for Strategic Advantage, challenged the audience to adopt the mindset required in a time of war. They argued that responding to Russian aggression requires greater urgency, coordination, and focus. They discussed how governments, regulators, companies, and civil society can work together more effectively to strengthen sanctions enforcement and increase pressure on Russia's war effort.
Richard Tornberg, Legal Counsel at Ericsson AB, offered a view from inside a large multinational, where sanctions compliance is not an abstract policy question but a daily operational challenge of judgement, monitoring, and risk management.
Measuring compliance and trade diversion
How can policymakers determine whether sanctions are being enforced effectively?
Erlend Bjørtvedt, Founder of Corisk, and Maria Perrotta Berlin, Assistant Professor at SITE, presented TRACER — the Trade Redirection and Circumvention Evaluation Ranking. The new index combines countries' institutional capacity with indicators of trade diversion to benchmark how effectively countries are preventing sanctions circumvention.
By linking institutional arrangements to observed trade outcomes, the project aims to provide policymakers with a more systematic way of identifying weaknesses in sanctions enforcement and monitoring potential circumvention routes.
New challenges in the digital economy
The conference also examined how cryptocurrencies and digital assets are changing the sanctions landscape.
Piotr Bobołowicz, Programme and Policy Advisor at the Global Coalition to Fight Financial Crime, provided an overview of how crypto assets can be used for sanctions evasion and highlighted regulatory and enforcement challenges.
SITE researcher Anna Anisimova presented new empirical evidence suggesting that cryptocurrencies have become an important link between Russian finance and global markets. Her research showed how crypto movements increasingly reflect financial stress in Russia and discussed both the achievements and remaining gaps in the European Union's latest sanctions package.
The discussion highlighted how sanctions policy must continue to evolve as financial technologies create new opportunities for cross-border transactions outside traditional banking systems.
From sanctions policy to sanctions enforcement
Although the conference covered a wide range of topics, participants repeatedly returned to the same conclusion: sanctions are only as effective as their implementation.
As Russia continues to adapt through alternative payment systems, intermediary countries, digital assets, and complex supply chains, effective sanctions enforcement increasingly depends on cooperation between governments, companies, researchers, and international partners.
Afternoon roundtable focused on practical cooperation
The conference concluded with a closed roundtable for Swedish authorities and companies, shifting the focus from analysis to implementation.
Lars Henriksson, Professor of Law at the Stockholm School of Economics, introduced the discussion by outlining companies' legal responsibilities in increasingly complex global supply chains. He highlighted the implications of the EU's anti-circumvention measures and Sweden's sanctions legislation, emphasizing the growing expectations placed on companies to understand where their products ultimately end up.
The second session, moderated by Anna Ekstedt, explored how Swedish authorities and businesses can strengthen cooperation on sanctions compliance and enforcement. Participants discussed information sharing, coordination mechanisms, and the practical challenges companies face when identifying and managing sanctions risks.
The discussion reflected one of the conference's central messages: preventing sanctions circumvention requires not only strong regulations but also continuous dialogue between policymakers, enforcement authorities, and the private sector.
As sanctions regimes evolve and circumvention methods become more sophisticated, that cooperation will remain essential to ensuring that sanctions achieve their intended effect.
Visit the Sanctions portal
Gain insights into sanctions on Russia and its economic retaliation measures. This resource provides a detailed timeline and comprehensive evidence base that brings together data, analysis, and expert commentary. It helps researchers, journalists, and policymakers navigate the evolving sanctions landscape. SITE Sanctions Portal explores the economic consequences of Western sanctions and Russia’s strategic responses.
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