Erasmus University Thesis Repository
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Sanctions against Russia for the aerospace industry
Sanctions imposed on Russia by the EU and U.S. since 2014, which intensified in 2022, have created a
complex regulatory landscape for businesses. These sanctions aim to weaken Russia's economy by
restricting access to critical technologies, items and markets, thereby limiting its military capabilities.
Since March 2022, regulations have evolved, with governments taking stronger stances on supply chain
accountability. A key development has been the focus on circumvention and diversion to close loopholes
and ensure sanctions effectively limit Russia’s military operations. This shift requires export control and
sanctions departments to monitor activities beyond export control classifications, including post-export
activities outside the companies’ direct control, adding unprecedented complexity.
This thesis evaluates how effectively aerospace companies, specifically Original Equipment
Manufacturers (OEMs) can comply with the sanctions against Russia, particularly concerning diversion
and circumvention. Literature highlights that the effectiveness of sanctions depends on the regulatory
environment, including the clarity of instructions and the capacity to monitor and enforce regulations