“I thank you for your commitment expressed at the highest level and steps already taken not to allow circumvention of EU sanctions vis-à-vis Russia,” reads the official letter, which the Georgian government received from EU Sanctions Envoy David O’Sullivan.

The letter released by the Georgian Ministry of Foreign Affairs is addressed to Foreign Minister Maka Botchorishvili and Minister of Economy and Sustainable Development Mariam Kvrivishvili.

The letter from the European Commission Directorate-General for Financial Stability, Financial Services and Capital Markets, signed by David O’Sullivan, underscores the Georgian government’s readiness and constant availability to address any question related to sanctions circumvention.

“I thank you for your commitment expressed at the highest level and steps already taken not to allow circumvention of EU sanctions vis-à-vis Russia, as well as for the constant availability of your authorities to address any question related to sanctions circumvention. I have previously shared with you a list of Common High Priority items (50 Harmonised System (HS) Codes) that the European Commission has prepared in close coordination with its partners. This list contains dual-use goods and advanced technology items under export restrictions that were retrieved in Russian military systems either found on the battlefield in Ukraine or critical to the development, production or use of those Russian military systems.

I thank for your efforts to stop the re-export of these items. In addition, the European Commission has identified a list of Economically Critical Goods (ECG) that Russia is desperately seeking to procure to support its war effort. These are sanctioned items that could support Russia’s industrial base. Even if most of these goods are not traditional dual-use items, the re-export of these products supports key sectors of the Russian economy. For example, appliances for pipes or specialised steel structures are needed for the Russian mineral resources industry. This sector is one of the main sectoral ‘contributors’ to Russia’s budget. Therefore, I respectfully request that you ban all the re-export of EU-origin items under the HS codes identified in the ECG list to Russia.

While Georgia is not a major re-exporter of these goods, countries in the region already found a way to address this issue, and there is a risk that Georgia becomes an alternative illicit trading route for these items. 2 We hope that this information will be useful for your relevant authorities to continue taking appropriate action so that sanctioned goods are not re-exported to Russia where they are diverted to support its war economy. Thank you for your urgent attention to this matter, and I look forward to receiving your response,” reads the letter.

Georgian Foreign Minister Maka Botchorishvili said that the Georgian government recently received a letter of appreciation from the European Union, recognising how well Georgia is adhering to its commitments and the conscientious manner in which the Georgian authorities are executing all activities to ensure that Georgia is not exploited to circumvent sanctions.