
The investigation sought to understand the company’s export of goods belonging to the Common High Priority List (CHPL), which are subject to more stringent export controls because of their potential use in Russian military hardware. An analysis of the company’s supply chain indicated that it had directly supplied CHPL components to Russia in 2022, including to companies linked to Russia’s defence manufacturing sector. Further analysis showed that its exports had shifted to Kazakhstan, a known sanctions evasion and transhipment hub, from 2023 onwards. The same analysis also identified that the company’s Kazakhstan-based buyers were selling the same components to a Hong Kong-based company which, in turn, was supplying companies in Russia. Further research into the original European company showed that it had been owned by a Belarusian national until Apr 2022, which highlighted an important red flag in Russia related sanctions. Taken together, Praetorian’s investigation uncovered serious compliance risks, enabling the client to fully assess the potential compliance risk exposure stemming from this company’s activities.

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