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Ukraine War

Russia Sanctions 2.0: Why Enforcement, Not Lists, Will Hurt Moscow

Putin Back in 2023 Speaking
Putin Back in 2023 Speaking. Image Credit: Creative Commons.

WARSAW, POLAND – The imposition of sanctions following Russia’s 24 February 2022 invasion of Ukraine was swift and was intended to have dramatic effects on Moscow’s economic situation.

The response from a coalition of Western nations, which included Australia, Canada, the European Union (EU), Japan, the UK, and the United States, was to impose a program of sanctions unprecedented in its severity.

These included restrictions on Russia’s financial sector to include the state central bank, removing Russia from the international SWIFT interbank transactions and payment system, and the imposition of new restrictions on goods and services that could be exported to Russia in conjunction with strategic sectors of the Russian economy.

Those included the aerospace industry, oil and gas, and international maritime shipping.

But the other dimension of this regime was to place sanctions on a large contingent of powerful officials and individual business figures, many of whom are long-time associates and/or allies of Russian President Vladimir Putin.

Also targeted were those involved in private military companies (ChVK), with the most prevalent among these being the Wagner Group.

Rounding out this collection were military officers, soldiers, and Russian Government officials in the occupied regions of Ukraine, plus oligarchs who were proven to be close to Putin, who were holding valuable assets in Western countries or had financial interests in Russian strategic industries.  (EU Commission, 2024).

To understand the extent of this network, there is an EU sanctions tracker, a United States tracker, and a searchable database maintained by the US Department of the Treasury’s Office of Foreign Assets Control (OFAC).

The UK also publishes a list of persons sanctioned under the 2018 Anti-Money Laundering Act, and there are also regular updates on measures taken to curb Russian aggression (UK government, 2025)

Adding to the Crimea and Donbas Embargoes

The 2022 package of sanctions aimed to establish an even more restrictive set of punitive measures, building on the sanctions initially introduced in 2014.

These were instituted in response to Russia’s annexation of Crimea and neighbouring regions.

Other policies have been implemented to penalize those responsible for enabling or creating mechanisms that facilitate circumvention or evasion of the sanctions regime.

Lastly, there have been those who have been singled out for the commission of war crimes and violations of human rights in occupied Ukrainian territories.

Russia Can Bust the Sanctions? An Explainer

But Russia is well-practiced in the art of sanction evasion.

During the Cold War, the USSR was legally prohibited from purchasing high-technology components, computer systems, and materials from the West.

Despite the export controls and other restrictions of the day, an international cooperative regime called COCOM, which was supposed to enforce these export bans, the USSR managed to purchase some of what it was looking to procure anyway.

In the post-Soviet era, these restrictions were all lifted. Still, since the war in Ukraine began, many of those technology export bans have been revived piecemeal in the form of specific, targeted sectoral sanctions.

The degree to which Vladimir Putin’s Russia is now circumventing many of them has generated calls for bundling all of those sanctions into a new, current-day version of those restrictions, which some officials have referred to as “COCOM 2.0”.

For now, Russia has managed to escape the full effects of some of these sanctions.

By way of example, the Kremlin has compensated for the significant reduction in oil pipeline exports to Western Europe with tanker-shipped oil to other countries, transported through a ‘shadow fleet’ of re-flagged vessels that illegally ship Russian petroleum.

What Kind of Sanctions Really Would be Effective

Two general categories need to be strengthened, which would have a significant impact on Russia’s ability to wage war if they were.

One is that there are no end of foreign components that Ukraine and other agencies inspecting unexploded or partially intact Russian weapons keep discovering on-board fighter aircraft, missiles, drones, etc.

Should the channels for procuring these piece parts and electronic systems be shut down entirely the effect on Russia’s defense sector would be dramatic.

The other significant “hole” in Western sanctions is that Russia continues to export oil, despite several restrictions and price caps.

In May, the BBC reported that the data they have analyzed show that Ukraine’s Western allies have paid Russia more for its hydrocarbons than they have given Ukraine in aid.

This has caused increasing numbers of organizations campaigning on Ukraine’s behalf to demand governments in Europe and North America take more stringent measures to keep Russian oil and gas from fuelling Moscow’s war.

In an interview more than six months ago, US President Donald Trump’s special envoy for Ukraine, retired Lt. Gen. Keith Kellogg, stated that sanctions enforcement on Putin is “only about a three” on a scale of one to 10 on how painful the economic pressure can be, he said in an interview with New York Post.

“You could really increase the sanctions — especially the latest sanctions,” which target oil production and exports.

About the Author: Reuben F. Johnson 

Reuben F. Johnson has thirty-six years of experience analyzing and reporting on foreign weapons systems, defense technologies, and international arms export policy. Johnson is the Director of Research at the Casimir Pulaski Foundation. He is also a survivor of the Russian invasion of Ukraine in February 2022. He worked for years in the American defense industry as a foreign technology analyst and later as a consultant for the U.S. Department of Defense, the Departments of the Navy and Air Force, and the governments of the United Kingdom and Australia. In 2022-2023, he won two awards in a row for his defense reporting. He holds a bachelor’s degree from DePauw University and a master’s degree from Miami University in Ohio, specializing in Soviet and Russian studies. He lives in Warsaw.

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Reuben Johnson
Written By

Reuben F. Johnson has thirty-six years of experience analyzing and reporting on foreign weapons systems, defense technologies, and international arms export policy. He is also a survivor of the Russian invasion of Ukraine in February 2022. He worked for years in the American defense industry as a foreign technology analyst and later as a consultant for the U.S. Department of Defense, the Departments of the Navy and Air Force, and the governments of the United Kingdom and Australia. In 2022-2023, he won two awards in a row for his defense reporting. He holds a bachelor's degree from DePauw University and a master's degree from Miami University in Ohio, specializing in Soviet and Russian studies. He lives in Warsaw.

3 Comments

3 Comments

  1. Jim

    September 28, 2025 at 3:15 pm

    Napoleon’s Continental System was hard to enforce and led to resentment against French rule and contributed to the eventual decline of Napoleon’s empire. (Plus invading Russia then fleeing all the way back to Paris, shorn his army.)

    It’s already worked so well, just try harder and it’s sure to work this time… we’ll find the magic formula this time. It’s bound to work this go around.

    It’s like looking for the tooth fairy.

    How long are we going to listen to stories about supposed pink unicorns? Just over the horizon.

    And how much money and lives get thrown down the sinkhole… waiting for the grand arrival of success this time?

    At some point it’s nothing but empty cant… like some old scratched record playing in the background.

  2. Swamplaw Yankee

    September 29, 2025 at 2:21 am

    When will enforcement concepts get actual funds, therefore, start! In the meantime, time swipes its blade edge across many throats.

    Meanwhile, any crazed orc ruuuzzkie genocider can enter the largest nuclear plant in europe, and set off the blade that will swipe across the throats of every European. No one can resist.

    Remember my favourite reference to the Ruuzzkie GNP of the past. Yeas, the sex trade cash makers, the mass abducted Ukrainian victims, were caravan bundled by ruuzzkies to the sex/slave fort of Caffa – the old money maker for the Italian state of Genoa.

    The Plague came in to Crimean Caffe from the mongols. The Plague was spread from there all across Europe, killing millions.

    So, the average ruuzzkie orc is close to crazed that the FREE Ukrainian real estate that they were promised by tsarling Putin may not be a clean steal. The theft of Ukrainian soil may be stopped and the thieves sent home with old refrigerators on their tanks.

    The super crazed ruuzzkie orc is able to freely enter + disable the few emergency generators that keep the 5 nuclear reactors from blowing sky high.

    Putin has already blown the regular electrical lines running from Ukraine into the nuclear plant.

    Any super crazed ruuzzkie orc can disable the emergency electrical generators! Nobody will even take a picture of the killer of millions. Nobody in MAGA POTUS Trump USA can ship in replacement generators in a short time frame. MAGA POTUS Trump may even deny to himself that the largest nuclear plant in Europe is on the cusp of a Super CHORNOBYL blowout!

    Democidist Putin is quite happy to send Lavrov out to Redline the MAGA POTUS elite and see the Trumpkins all collapse in nervous breakdowns.

    Somehow, the MAGA POTUS is incapable of protecting the WEST from this permanent threat of radioactivity. As the MAGA elite pick at their belly buttons, time swipes the sharp blade edge with kinetic force.

    At such times, the USMC and/or Seals must be deployed into Ukraine to save Europe. That is, the USMC/Seals must secure and deploy around this nuclear facility in a time sensitive military move. With the import of skilled nuclear technicians the emergency generators must be rescued and remain able to generate the electrical power levels to stop the next nuclear Fukashima Blowout!

    The Ukrainians would be willing to re-construct mainline transmission lines from Ukrainian soil that Democidist Putin has not yet thieved for his orcs.

    Or, the MAGA POTUS elite can do zip, zero, nothing, but invite Lavrov to show off more redlines as he lowers his ruuzzkie pants. That should paralyze the US State Department as commie redlines have for the last 100 years.

    That the MAGA POTUS elite refuse to fund effective, efficient sanction enforcement of technology is evident to every world leader + their peoples. That the oil/ natural gas from Killer Putin sloshes all over the world is also obvious, especially since once it spills.

    Look, MAGA POTUS + his elite kept their collective mouths shut when Chornobyl was penetrated. Now, the MAGA POTUS can easily kill off Europe and, best, in the MSM blame the Europeans. -30-

  3. Jim

    September 29, 2025 at 1:10 pm

    Sunday has brought an update. The Sunday morning talk shows (politics) put on retired General Keith Kellog and Vice-President J. D. Vance, both members of the administration gave no indication the present Bidenesque Ukraine policies will change.

    Both Kellog and Vance stated Tomahawk missiles are a distinct possibility, particularly Kellog, although, both suggested Trump hasn’t made a final decision on the Tomahawks.

    And, of course, denying Russia even has an offer on the table, of which they do indeed.

    Starting with neutrality and so on.

    Trump denies the Russians have on offer on the table because he doesn’t want to address the issue of neutrality publicly.

    The goal of imposing the Keith Kellog Peace Plan with a line of demarcation with remaining Ukrainian territory West of that line being NATO-ized is alive and well.

    The war drags on with no end in sight.

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