Treasury Calls Out UAE for Sanctions Busting


Elizabeth Rosenberg, the assistant Treasury secretary for terrorist financing and financial crimes, added to the drumbeat of criticism of sanction dodging regimes, telling a meeting of Women in International Trade that the UAE was a “country of focus” for the US.

"Our sanctions have played an important part in this very broad effort. From the beginning, they have been designed to constrain the wealth and weapons available to Putin to fight his war—and to do so in a way that minimizes the harm to our own economy.  

"But Russia will look for ways to work around our measures. The coming year will be about ensuring that our sanctions architecture is fully enforced and effective—in particular, by figuring out and cracking down on the ways Russia evades sanctions. Furthermore, we will deploy new and novel ways of complementing trade controls with financial constraints to shut down the evasion and shadowy economic activity Russia seeks to sustain its war efforts.

"We are specifically concerned about increases in trade with Russia in the kind of goods that can be used on the battlefield and those who are aiding designated Russian entities. We are investigating this type of assistance at the individual, firm, and sector level. We will engage companies, banks, regulators, and service providers in a series of jurisdictions we assess are wittingly or unwittingly providing assistance to Russia. This is a broad campaign on which we are working closely with allies and partners.

"To give you an example from one country of focus for us: we are concerned that between July and November of 2022 United Arab Emirates (UAE) companies exported over $18 million worth of goods to U.S.-designated Russian entities.

"Also, between June and November of 2022, UAE companies exported over $5 million worth of U.S.-origin, U.S.-export controlled goods to Russia, including but not limited to semiconductor devices, some of which can be used on the battlefield.

"This is about making the choice clear to companies and banks: you can do business with the countries that constitute more than 50 percent of the world’s GDP, and its most convertible and stable currencies, or do business with those who facilitate Russia’s war."


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