Asian trading networks continue to route European-made dual-use technology into Russia’s war economy, exploiting gaps in the continent’s sanctions designations and enforcement, according to new research published by the Committee for Freedom in Hong Kong (CFHK) Foundation.

The 104-page report, “Bypassing the Blockade: How Hong Kong Feeds European Technology Into Russia’s War in Ukraine,” draws on three main datasets: Russian customs records, a Ukrainian Defense Ministry database cataloguing foreign components recovered from Russian military equipment, and Hong Kong corporate records used to trace suppliers, owners, and affiliated companies. 

The research draws on “more than $200 million of high-priority European technology” identified in Hong Kong–Russia customs data, CFHK said. 

That dual-use goods are making their way into Russian hands can be seen on the battlefield. As of October 2025, the Ukrainian battlefield components database listed 693 components of EU, U.K., or Swiss origin recovered from Russian weapons or associated military electronics, including 322 Swiss-origin items and 146 from the Netherlands. 

Citing Russian customs records from March 2022 through February 2024, the report also identifies 19,907 Hong Kong-to-Russia shipments of European-origin goods on the Common High Priority List. The items were sourced to more than a dozen countries in Europe, with Germany accounting for the largest share.

A relatively small set of Hong Kong intermediaries appear to be playing an outsized role in the shadow supply chains, in part due to sanctions gaps, according to CFHK, which cited Woeroon Electronic Sourcing Ltd. and an affiliated Shenzhen entity as an example. 

Woeroon appeared as a top-five supplier for goods linked to 18 European manufacturers, yet remained unsanctioned by the EU, UK, Switzerland, or the U.S. despite the volume of trade identified.

According to Russian customs records, Woeroon was involved in 25,707 shipments of high-priority goods from Hong Kong to Russia valued at about $27.9 million between 2022 and 2024, with more than half classified under integrated-circuit customs categories. Approximately 60% of those shipments went to Russian importer OOO Orka/Orca, and another 31% to OOO Altrabeta.  

OOO Altrabeta is subject to U.S. sanctions, while OOO Orka/Orca is not currently sanctioned, according to the foundation, which also highlighted a number of companies that appear to be operationally linked to Woeroon in Hong Kong and Shenzhen.

The report argues that sanctions programs among Ukraine’s European allies are “fragmented” and often too narrowly aimed at single legal entities rather than corporate networks, allowing activity to shift to affiliates when one company is designated. 

Among other steps, CFHK recommends that sanctions enforcement take aim at the facilitating companies, such as banks and logistics firms, that enable networks to operate despite sanctions. European nations should also coordinate more on designations and enforcement and consider designating Hong Kong a high-risk jurisdiction for money laundering, the report said. 

“The evidence in this report demonstrates that Europe and its allies have not yet translated political alignment into operational alignment,” the foundation said. “Until they do, companies like Woeroon and the Hong Kong authorities that enable them will continue to adapt faster than the systems designed to stop them.” 

Read the full report here