POSITION | EXTERNAL ECONOMIC POLICY | SANCTIONS
Sanctions Enforcement Government commitment must complement companies' compliance efforts
April 25, 2023 Sanctions must have an effect The situation has remained unchanged for over a year: Russia is waging war in Ukraine with the aim of eliminating the country's statehood. This brazen violation of international law must not be tolerated. German industry stands by Ukraine. We support the sanctions and the foreign and security policy objectives they serve. Enforcement of the EU-Russia embargo must be a joint task German companies have made enormous efforts since the start of the war and have implemented the EU's Russia embargo. Many companies have gone beyond the sanctions measures and voluntarily withdrawn from the Russian market. Because corporate and governmental export control structures interact effectively in the Federal Republic of Germany, the business community has been able to fulfill its obligations in an exemplary manner. This likewise holds true with respect to EU sanctions on indirect goods exports, as was underlined by the 2022 foreign trade audits. Nevertheless, it is clear that despite the existing sanctions, goods are unintentionally entering the Russian Federation and that the latter has created a complex system to avoid trade restrictions. Unfortunately, the number of states sanctioning Russia has remained relatively limited at just under 50. Countries that account for around 60 percent of the world economy and two-thirds of the world's population do not sanction Russia. This means that in a world of global economic flows the sum of potential evasion options is simply too great for trade controls against Russian procurement efforts to be implemented by individual economic operators alone. The German business community therefore rejects the means of a "transparent end-use certificate" proposed by the Federal Ministry of Economics in February, and instead calls for the government to take on responsibility more directly and to support economic operators by providing so-called "blacklists".