Current and former U.S. officials say that some shipments into Russia are to be expected. Kevin Wolf, a partner at the law firm Akin Gump who oversaw export controls during the Obama administration, said the restrictions “can never block everything,” but that the rules were still significantly degrading Russia’s capabilities.
He added that the scope of the new rules still exceed current methods of tracking and enforcement in other allied countries. Until the invasion of Ukraine, trade in aircraft parts was mostly unrestricted by the United States and other countries, except to Iran, Cuba, North Korea and Syria.
“It’s improving,” Mr. Wolf said, “but it’s still way, way behind.”
Compared with other countries that mostly limit their scrutiny to goods crossing their own borders, the United States is unparalleled in its attempt to police commerce around the world.
In the past three years, the United States has imposed new technology restrictions for Russia, China and Iran that apply extraterritorially: Products made in the United States, or in foreign countries with the help of American components or technology, are subject to U.S. rules even when changing hands on the other side of the world.
Both the United States and the European Union have been ramping up penalties for companies that violate sanctions, and dispatching officials to countries like Kazakhstan to try to persuade them to clamp down on shipments to Russia through their territory. The U.S. government has nine export control officers stationed in Istanbul, Beijing and other locations to trace shipments of sensitive products, and it is setting up three more offices.
But providing parts can be a lucrative business. James Disalvatore, an associate director at Kharon, a data and analytics firm that has been monitoring Russia’s efforts to bypass sanctions, said the value of some aircraft parts imported by Russian airlines since the invasion had risen fourfold or more.
“I don’t think there’s any secret what’s going on,” said Gary Stanley, a trade compliance expert who advises businesses in aerospace and other industries. “How long have we had Cuban sanctions? How long have we had North Korean sanctions? How long have we had Iranian sanctions? It never seems to put these folks out of business.”
