BAKU, Azerbaijan, September 17. Several non-governmental organizations (NGOs) of Azerbaijan have sent an open letter to key officials in the United States and the European Union, expressing deep concern over Armenia's actions that facilitate Russia's evasion of international sanctions imposed due to the conflict with Ukraine, Trend reports.
The letter reads:
"Janet L. Yellen, Secretary of the Treasury, which oversees the Office of Foreign Assets Control (OFAC) of the United States.
Alan F. Estevez, Under Secretary for Industry and Security at the US Department of Commerce.
Merrick Garland, Attorney General of the United States.
Josep Borrell, High Representative of the European Union for Foreign Affairs and Security Policy.
Charles Michel, President of the European Council.
We, the non-governmental organizations (NGOs) of Azerbaijan, signed below, express our serious concern over the activities of the Republic of Armenia, which create conditions for Russia to evade international sanctions imposed due to the war with Ukraine. These sanctions, imposed by Western countries, aim to hold Russia accountable and prevent a humanitarian crisis. By conducting hypocritical policies, the Armenian authorities violate international law and, by supporting Russia in evading sanctions, deepen the humanitarian crisis in Ukraine.
Since the war between Russia and Ukraine began in 2020, there has been a sharp increase in Armenia's imports and exports, which is disproportionate to its economic potential. Authoritative international reports particularly highlight the multiple-fold increase in Armenia’s foreign trade turnover with Russia as the scope of the sanctions package imposed on the Russian Federation by the EU and the US expanded.
The sharp change in Armenia’s commodity-geographic structure of foreign trade between 2021-2023 is due to evading sanctions imposed on the Russian Federation by Western countries. In 2021, Armenia’s foreign trade turnover with the Russian Federation grew by 24.2 percent compared to 2020 — to $2.6 billion; in 2022 — to $5 billion, increasing by 93.4 percent compared to 2021; and in 2023 — by 45.7 percent compared to 2022 — to $7.3 billion. Russian Deputy Prime Minister Alexey Overchuk stated at a meeting of the intergovernmental commission on economic cooperation between Russia and Armenia that foreign trade turnover between the two countries would reach $14-16 billion in 2024. If this forecast is realized, overall foreign trade turnover between Armenia and the Russian Federation in 2024 compared to 2020 will increase up to 8 times.
According to the publication of the Armenian State Statistics Committee, exports of goods to the Russian Federation in 2022 reached a historical record level in 2021, increasing 3 times to $2.4 billion, and in 2023 — by 43.1 percent compared to 2022 — to $3.4 billion. From 2010-2020, the growth rate of exports from Armenia to Russia averaged 18.6 percent; in 2020-2023, this indicator reached 64 percent.
Before 2021, the share of the Russian Federation in Armenia’s goods and product exports did not exceed 27 percent; during 2022-2023, the share of the Russian Federation increased to 40-44 percent. This is because Armenia, evading sanctions, imports goods and products from several EU countries, Persian Gulf states, and leading Asian countries for export to Russian markets.
Thus, during 2023, 14.7 percent ($499 million) of the goods exported from Armenia to the Russian Federation were telephone devices and equipment for mobile and wireless networks, 11.1 percent ($378 million) were passenger cars, 7.39 percent ($250 million) were monitors and projectors, 2.54 percent ($86 million) were computing machines, their blocks, and magnetic and optical computing devices, and 1 percent ($31 million) were vacuum equipment.
In total, 91 percent of electromechanical and machine equipment in Armenia’s exports is supplied to Russian markets. Furthermore, in 2023 compared to 2022, exports of nuclear reactors, equipment, and mechanical devices from Armenia to the Russian markets increased 10 times, exports of optical, photographic, cinematographic, and medical surgical instruments increased 5 times, exports of aircraft, spacecraft, and their parts increased 2 times, exports of ships, boats, and floating structures increased 18 times, exports of musical instruments increased 38 times, exports of all types of watches increased 28 times, and exports of art objects and collectibles increased 19 times.
Since none of the mentioned goods are produced in Armenia, the export of most of these goods to the Russian Federation did not occur before 2022.
Despite the European Union’s sanctions against the Russian Federation, some EU countries continue foreign trade operations with the Russian Federation through Armenia. Notably, in 2023 compared to 2021, trade between Armenia and the European Union increased 2.4 times.
There is a noticeable increase in relations with some Eurozone countries. For instance, in 2023 compared to 2021, Armenia’s exports to Greece increased 39 times, and exports to Cyprus increased 24 times. How is it possible that while the EU and the US impose sanctions against Russia, countries responsible for enforcing these sanctions participate in illegal trade through Armenia? Indirectly, Armenia is financing Russia’s war in Ukraine, providing Russia with a "loophole" in foreign trade.
The first EU sanctions against Russia have been periodically updated and extended since their adoption in March 2014. On November 28, 2022, the European Council unanimously adopted a regulation adding "violation of EU sanctions" to the list of "EU crimes" mentioned in the Treaty on the Functioning of the European Union ("TFEU").
One of the elements of the 11th EU sanctions package, adopted on June 23, 2023, isolating Russia from Western economies, includes control and restriction of import-export operations as a special means of combating tax evasion. The list of those supporting Russian aggression against Ukraine, attached to this sanctions package, also includes information about a legal entity registered in Armenia (Annex 4 to EU Regulation No. 833/2014).
On June 24, 2024, the European Union adopted its Regulation 2024/1745, considered an amendment to its Regulation 833/2014, containing the 14th package of restrictive measures, including trade sanctions. This package of restrictive measures requires EU parent companies to ensure that their subsidiaries in third countries do not engage in any activities that could violate sanctions, prohibits the provision of liquefied natural gas transportation services owned by Russia from the EU to third countries, introduces a sectoral ban on vessels participating in Russia’s war against Ukraine, denies access to ports and locks of member states, and imposes a wide range of maritime transport services restrictions.
As outlined in EU Regulation No. 2024/1745, Decision No. 2024/1744 ("CFSP") imposes additional restrictions on the export of goods that could contribute to the enhancement of Russia’s industrial potential. Regulation No. 2024/1745 also allows citizens and companies from EU member states to seek compensation for damages caused by Russian companies as a result of sanctions and confiscation.
Additionally, "CAATSA", the US federal law effective from August 2, 2017, the "Countering America’s Adversaries Through Sanctions Act", establishes sanctions against the Russian Federation to combat terrorism and illegal financing (Chapter II, Sections 201–259). Section 232 of this act defines sanctions related to pipeline development in the Russian Federation, Section 233 addresses sanctions on investments or assistance in the privatization of state assets by the Russian Federation, and Section 226 covers sanctions on Russian and other foreign financial institutions.
As supporters of peace, stability, and the rule of international law, we urge the United States and the European Union, which have imposed sanctions, to take the following steps:
Strengthen control over Armenia’s trade operations. We demand a stricter regime for inspecting goods imported and exported by Armenia, ensuring transparency in this area, particularly to prevent illegal trade in goods used in the war.
Ensure enforcement of sanctions. We call on Western governments to enforce existing sanctions more rigorously and to impose targeted sanctions or trade restrictions on any state that assists in evading sanctions, including Armenia.
Increase diplomatic pressure on Armenia. We recommend that Western countries intensify direct diplomatic efforts to urge Armenia to cease its support for Russia, remind Armenia of its obligations under international law, and the need to adhere to the principles of peaceful coexistence.
Continued Armenian support for Russia weakens global efforts to restore peace and stability in Ukraine and contributes to violations of international law. We believe that a unified and decisive position from the international community is crucial to ending Armenia’s activities in this direction and enhancing the effectiveness of sanctions imposed against Russia.
We hope you will consider our concerns and take appropriate measures to prevent further exacerbation of the conflict in Ukraine by Armenia.
We appeal to you: Stop allowing Armenia to create conditions for Russia to evade sanctions!
Signatures:
Sabit Bagirov — Head of the Foundation for the Promotion of Entrepreneurship and Market Economy
Vladimir Timoshenko — Retired Major General, Member of the Presidium of the Veterans Organization of the Republic of Azerbaijan
Karamat Ismayilov — Chairman of the Public Association Center for Economic and Social Development
Nigar Alekberova — Chairwoman of the Association of Small and Medium Business Entities and Clubs
Zaur Ibrahimli — Board Member of the Azerbaijani National Forum of NGOs
Fikret Yusufov — Chairman of the Public Association for International Economic Research "Ekonomiks"
Eyyub Kerimli — Chairman of the Public Association for Economic and Social Research
Ruslan Atakishiyev — Chairman of the Public Association for the Study of Economic Resources
Sakina Babayeva — Chairwoman of the Association for the Development of Women’s Entrepreneurship in Azerbaijan
Gunay Shahbazova — Chairwoman of the Azerbaijan Association of Accountants and Risk Specialists".