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A coalition of Azerbaijani NGOs has delivered an open letter to the leaders of significant agencies tasked with enforcing sanctions against Russia in the U.S. and the EU.

Azernews presents the letter:

Honorable James David Vance, Vice President of the United States

Honorable Marco Antonio Rubio, US Secretary of State

Honorable Scott Bessent, US Secretary of the Treasury

Honorable Jeremy Pelter Acting US Secretary of Commerce

Honorable Pamela Jo Bondi, Attorney General of the United States

Honorable António Costa, President of the European Council

Honorable Ursula von der Leyen, President of the European Commission

Honorable Kaja Kallas, EU High Representative for Foreign Affairs and Security Policy

We, the undersigned non-governmental organizations (NGOs) of Azerbaijan, write to express our deep concern regarding the activities of the Republic of Armenia, which have been enabling Russia to bypass international sanctions imposed in response to the ongoing war in Ukraine.

Since the war began in 2022, Armenia, a country with one of the smallest foreign trade turnovers in the South Caucasus, has experienced a drastic and disproportionate increase in both imports and exports, far exceeding its economic capacity. In 2021, Armenia's trade with Russia stood at $2.5 billion USD. By 2024, this surged up to fivefold, reaching $12 billion USD. Notably, Armenia's exports to Russia, which had remained below 27% of total exports until 2021, surged to between 40-44% in 2022 and 2023. Furthermore, by November 2024, Armenia’s primary export markets shifted to Gulf countries, largely driven by the re-export of precious metals from Russia.

This sharp increase in trade, particularly the export of high-tech goods, raises significant concerns about the diversion of these products for military use. Armenia’s exports to Russia in 2024 included a range of electronics—such as semiconductors, smartphones, communication devices, and other high-tech equipment—that go far beyond what Armenia's economy is capable of producing. This suggests a potential violation of sanctions by facilitating the transfer of goods that may support Russia’s military efforts in Ukraine.

Both the U.S. and European Union have repeatedly strengthened their sanctions regimes against Russia, including through the introduction of multiple sanction packages. The European Union, which initially imposed sanctions in March 2014, has continuously expanded these measures. The most recent, the 14th and 15th packages in 2024, focus on preventing third countries from indirectly aiding Russia through the use of subsidiaries. Similarly, U.S. sanctions under the Countering America's Adversaries Through Sanctions Act(CAATSA) and the National Defense Authorization Acts (NDAA) have also targeted foreign entities assisting Russia, with secondary sanctions extending to third-country actors like Armenia.

Despite these efforts, Armenia’s growing role in evading sanctions highlights a significant loophole that undermines the impact of these sanctions on Russia. In response to this situation, we urge the U.S. and the EU to take the following steps:

Tighten Oversight of Armenia’s Trade: We call for stronger monitoring of Armenia’s imports and exports, ensuring greater transparency and preventing illegal trade in military-related goods. This includes more rigorous checks on products that could potentially be used in Russia’s war efforts. Enhance Sanctions Enforcement: It is imperative that the U.S. and EU governments enforce existing sanctions more strictly. We urge them to impose targeted sanctions or trade restrictions on Armenia for its role in facilitating sanctions evasion and to take decisive action against any state helping Russia bypass international measures. Increase Diplomatic Pressure on Armenia: We call on Western governments to intensify their diplomatic efforts to persuade Armenia to cease supporting Russia. Armenia must be reminded of its obligations under international law and its responsibility to adhere to the principles of peace and coexistence.

Armenia's continued support for Russia is not only prolonging the war in Ukraine but also undermining international efforts to restore peace and stability. The failure to hold Armenia accountable for its actions encourages further violations of international law and weakens the sanctions regime.

We firmly believe that a united and resolute stance from the international community is crucial to halting Armenia’s actions and reinforcing the effectiveness of sanctions against Russia. We hope that you will consider our concerns and take the necessary steps to prevent Armenia from exacerbating the conflict in Ukraine.

In conclusion, we urgently appeal to you: Stop Armenia from enabling Russia’s sanctions evasion!

Sincerely,

Zaur İbrahimli – Member of the Executive Board of the National NGO Forum of Azerbaijan

Sabit Baghırov – Head of the Fund for the Development of Entrepreneurship and Market Economy

Vladimir Timoshenko – Retired Major General, Member of the Board of Veterans of War, Armed Forces, and Labor of the Republic of Azerbaijan

Keramet Ismayılov – Chairman of the Public Union for Economic and Social Development

Gunay Shahbazova – President of the Association of Azerbaijani Accountants and Risk Professionals

Ramin Sharifov – Chair of the Association of Small and Medium-sized Business Entities and Clubs

Fikret Yusifov – President of the "Economics" International Economic Research Public Union

Sakina Babayeva – President of the Women Entrepreneurs Development Association of Azerbaijan

Ruslan Atakishiyev – President of the Public Union for Economic Resource Studies

Eyyub Karimli – President of the Public Union for Economic and Social Research Assistance