Azerbaijani (NGOs) Non-Governmental Organizations have sent an open letter to the leaders of key institutions responsible for implementing and monitoring sanctions against Russia in the U.S. and the European Union.
Axar.az reports that the letter addressed to Janet L. Yellen, the head of the U.S. Treasury Department's Office of Foreign Assets Control; Alan F. Estevez, the head of the U.S. Department of Commerce's Bureau of Industry and Security; Merrick B. Garland, the head of the U.S. Department of Justice; Ursula von der Leyen, President of the European Commission; Josep Borrell, High Representative of the European Union for Foreign Affairs and Security Policy; and Charles Michel, President of the European Council, states:
“We, the undersigned Azerbaijani NGOs, are writing to express our serious concern about the activities of the Republic of Armenia, which facilitate the circumvention of international sanctions imposed on Russia in connection with the Ukraine war. These sanctions, imposed by Western countries, aim to hold Russia accountable and prevent a humanitarian crisis. The Armenian government is conducting a double-dealing policy, violating international law, and supporting Russia in evading sanctions, thereby exacerbating the humanitarian crisis in Ukraine.
Since the war between Russia and Ukraine began in 2022, Armenia, with the smallest foreign trade turnover in the South Caucasus, has seen a sharp increase in both imports and exports that does not match its economic potential. As the scope of the sanctions package imposed by the European Union and the U.S. on the Russian Federation expands, the multiple increases in Armenia's foreign trade turnover with Russia are highlighted in credible international reports.
The significant changes in Armenia's foreign trade structure between 2021-2023 are related to the circumvention of sanctions imposed on the Russian Federation by Western countries. In 2021, Armenia's foreign trade turnover with the Russian Federation increased by 24.2% compared to 2020, reaching 2.6 billion USD. In 2022, it increased by 93.4% compared to 2021, reaching 5 billion USD. In 2023, it rose by 45.7% compared to 2022, reaching 7.3 billion USD. Russia's First Deputy Prime Minister Alexei Overchuk stated that the foreign trade turnover between Russia and Armenia is expected to reach 14-16 billion USD in 2024. If this forecast is realized, the foreign trade turnover between Armenia and the Russian Federation will increase up to 8 times compared to 2020.
According to the publication of the Armenian National Statistical Committee, Armenia's exports to the Russian Federation in 2022 tripled compared to 2021, reaching a historic record of 2.4 billion USD. In 2023, exports increased by 43.1% compared to 2022, reaching 3.4 billion USD. The average growth rate of exports from Armenia to Russia from 2010-2020 was 18.6%, whereas from 2020-2023, this rate reached 64%.
Until 2021, the share of the Russian Federation in Armenia's exports did not exceed 27%, but in 2022-2023, it rose to 40-44%. This increase is due to Armenia's import of goods from several EU countries, the Arab Gulf, and leading Asian states for the purpose of exporting to the Russian market. For example, in 2023, 14.7% (499 million USD) of Armenia's exports to the Russian Federation consisted of telephone apparatus, 11.1% (378 million USD) of passenger cars, 7.39% (250 million USD) of monitors and projectors, 2.54% (86 million USD) of calculating machines and their blocks, and 1% (31 million USD) of vacuum cleaner equipment. Overall, 91% of Armenia's exports in electromechanics and machinery are sent to the Russian market. Additionally, compared to 2022, the export of nuclear reactors, equipment, and mechanical devices to the Russian market increased 10 times in 2023, optical, photographic, cinematographic, and medical-surgical instruments 5 times, aircraft, spacecraft, and their parts 2 times, ships, boats, and floating structures 18 times, musical instruments 38 times, all types of watches 28 times, and art and collectible items 19 times. None of these goods were produced in Armenia, and most of these products were not exported to Russia before 2022.
Despite the EU's sanctions against the Russian Federation, several EU countries continue foreign trade operations with Russia through Armenia. For example, trade between Armenia and the EU increased 2.4 times in 2023 compared to 2021. Significant increases are observed in relations with some Eurozone countries. In 2023, exports from Armenia to Greece increased 39 times, and to Cyprus 24 times compared to 2021. How can it be that while the EU and the U.S. impose sanctions on Russia, countries responsible for implementing these sanctions are involved in illegal trade with Russia through Armenia? Armenia is effectively providing Russia with a "breathing space" in foreign trade and financing its war in Ukraine.
Since the EU first imposed sanctions on Russia in March 2014, these sanctions have been periodically updated and extended. On November 28, 2022, the European Council unanimously adopted a decision adding "breach of EU sanctions" to the list of "EU crimes" referred to in the Treaty on the Functioning of the European Union (TFEU). The EU's 11th sanctions package, adopted on June 23, 2023, includes elements related to import-export operation controls and restrictions as a special measure to combat evasion. The list of supporters of Russia's aggression against Ukraine in this sanctions package includes information about a legal entity registered in Armenia (Annex IV to Regulation 833/2014).
On June 24, 2024, the EU adopted Regulation 2024/1745, which includes the 14th restrictive measures package considered an amendment to Regulation 833/2014 and includes trade sanctions. This restrictive measures package requires EU parent companies to ensure that their subsidiaries in third countries do not engage in activities that could breach sanctions, prohibits the transportation of Russian liquefied natural gas from the EU to third countries, and applies sectoral bans preventing ships contributing to Russia's war against Ukraine from accessing member states' ports and locks, as well as a broad range of maritime services.
As described in the EU Regulation 2024/1745, Decision 2024/1744 (CFSP) imposes additional restrictions on the export of goods that could contribute to the enhancement of Russia's industrial capabilities. Regulation 2024/1745 also allows EU member states' citizens and companies to claim compensation for damages caused by sanctions and confiscations from Russian companies.
Additionally, CAASTA, a U.S. federal law effective from August 2, 2017, the Countering America's Adversaries Through Sanctions Act, establishes sanctions for Russia, terrorism, and combatting illicit financing (Title II, Sections 201-259). Section 232 of this act includes sanctions related to pipeline development in Russia, Section 233 addresses investment or promotion of investment related to the privatization of state property in Russia, and Section 226 outlines sanctions against Russian and other foreign financial institutions.
As supporters of peace, stability, and the rule of international law, we call on the U.S. and the European Union to take the following actions:
- Increase control over Armenia's trade operations! We demand stricter inspection of the goods imported and exported by Armenia, increased transparency in this area, and prevention of illegal trade in war-related goods.
- Ensure the enforcement of sanctions! We call on Western governments to implement stricter enforcement of existing sanctions and impose targeted sanctions or trade restrictions on any state, including Armenia, that helps evade sanctions.
- Strengthen diplomatic pressure on Armenia! We recommend that Western countries increase their direct diplomatic efforts to urge Armenia to stop supporting Russia, reminding Armenia of its obligations under international law and principles of peaceful coexistence.
Armenia's continued support for Russia undermines global efforts to restore peace and stability in Ukraine and promotes violations of international law. We believe that a united and decisive stance from the international community is crucial to stop Armenia's activities in this direction and enhance the effectiveness of sanctions imposed on Russia.
We hope that you will consider our concerns and take appropriate measures to prevent Armenia from further deepening the conflict in Ukraine.
We urgently appeal to you: Stop allowing Armenia to create conditions for Russia to evade sanctions!"
Signatures:
- Sabit Bağırov - Head of the Fund for the Development of Entrepreneurship and Market Economy
- Vladimir Timoşenko - Retired Major General, Member of the Presidium of the Azerbaijani War, Armed Forces, and Labor Veterans Organization
- Kəramət İsmayılov - Chairperson of the Public Union for Economic and Social Development Center
- Nigar Ələsgərova - Chairperson of the Association of Small and Medium Business Entities and Clubs
- Zaur İbrahimli – Member of the Board of the Azerbaijani National NGO Forum
- Fikrət Yusifov – Chairperson of the "Economics" International Economic Research Public Union
- Əyyub Kərimli - Chairperson of the Public Union for Economic and Social Research Support
- Ruslan Atakişiyev - Chairperson of the Public Union for the Study of Economic Resources
- Səkinə Babayeva - Chairperson of the Association for the Development of Women Entrepreneurship in Azerbaijan
- Günay Şahbazova - Chairperson of the Azerbaijani Association of Accountants and Risk Professionals
