Recommendation 9

We are concerned about growing evidence that Russia has been able to circumvent sanctions through third states and uninsured shadow tanker fleets. We welcome the Government’s efforts to address this, in cooperation with our partners and allies, and in the current format of cooperation between envoys. Since the lifting of sanctions on Russia appears to be a distant prospect, circumvention will remain a challenge requiring ongoing cooperation. We urge the Government, when replying to this report, to list the measures already taken in response to circumvention; and to set out their plans for more effective enforcement, including through closer and more effective cooperation with the EU and its Member States.