EU Sanctions Envoy thanks Georgian Government for preventing EU sanctions evasion

EU Sanctions Envoy David O'Sullivan on Wednesday sent an official letter to the Georgian Government praising its high-level commitment and concrete actions to block the circumvention of EU sanctions on Russia.

In a formal letter addressed to Georgian Foreign Minister Maka Botchorishvili and Georgian Economy Minister Mariam Kvrivishvili, O'Sullivan expressed gratitude for Georgia’s proactive stance in enforcing EU export controls.

“I thank you for your commitment expressed at the highest level and steps already taken not to allow circumvention of EU sanctions vis-à-vis Russia, as well as for the constant availability of your authorities to address any question related to sanctions circumvention”, he said.

O'Sullivan referenced a shared list of high-priority items – including dual-use technologies found in Russian weapons on Ukrainian battlefields – and thanked Georgia for stopping their re-export.

“I have previously shared with you a list of Common High Priority items (50 Harmonised System (HS) Codes) that the European Commission has prepared in close coordination with its partners. This list contains dual-use goods and advanced technology items under export restrictions that were retrieved in Russian military systems either found on the battlefield in Ukraine or critical to the development, production or use of those Russian military systems. I thank you for your efforts to stop the re-export of these items”, he noted.

Additionally, he outlined a new category of economically critical goods, such as pipeline equipment and specialised steel, that bolster Russia’s war-sustaining industries.

“In addition, the European Commission has identified a list of Economically Critical Goods (ECG) that Russia is desperately seeking to procure to support its war effort. These are sanctioned items that could support Russia’s industrial base. Even if most of these goods are not traditional dual-use items, the re-export of these products supports key sectors of the Russian economy. For example, appliances for pipes or specialised steel structures are needed for the Russian mineral resources industry. This sector is one of the main sectoral contributors to Russia’s budget. Therefore, I respectfully request that you ban all the re-export of EU-origin items under the HS codes identified in the ECG list to Russia”, the letter said.

While acknowledging Georgia is not a major re-exporter, O'Sullivan warned of the risk of diversion and urged a ban on re-exporting all listed EU-origin items to mitigate potential loopholes.

“While Georgia is not a major re-exporter of these goods, countries in the region have already found a way to address this issue, and there is a risk that Georgia becomes an alternative illicit trading route for these items. We hope that this information will be useful for your relevant authorities to continue taking appropriate action so that sanctioned goods are not re-exported to Russia where they are diverted to support its war economy. Thank you for your urgent attention to this matter, and I look forward to receiving your response”, O'Sullivan concluded.