Rows of residential buildings in the Belgrade suburb of Rakovica, built in the seventies, stretch endlessly.
There, on the sixth floor of the building in Nikola Marakovića Street, the company "Kominvex" is registered.
It is a company that, from the beginning of the invasion of Ukraine until August 2023, in less than a year and a half, exported goods worth more than 140 million dollars to Russia, according to data obtained by Radio Free Europe (RSE).
A third of the exported products, that is goods worth more than 50 million dollars, according to the customs markings, are electronic components that are on the sanctions of the European Union because they can be used in the military industry.
The numbers speak of a large trading firm, but there is no sign on the building where it is registered.
No one answers the intercom or the bell outside the door of apartment number 36.
According to RSE research, "Kominvex" is one of dozens of companies registered in Serbia that have been exporting products to Russia since the beginning of the war in February 2022.
Based on data from international trade databases, RSE analyzed more than 14.000 shipments that arrived in Russia during this period.
These databases show that products worth at least 71,1 million dollars were delivered through Serbian companies, although they are goods that have been placed on the list of high-risk products and are on the sanctions imposed by the European Union and the United States of America on Russia.
Since the beginning of the war in Ukraine, Serbia has not agreed to any decision on sanctions against Russia.
A months-long research by RSE reveals how in such a vacuum, without legal restrictions, some Serbian companies earned millions.
The most modern Western goods through Serbian companies in Russia
As RSE research showed, the most modern technological products reached customers in Russia through Serbian papers.
In some cases, it was the goods of the largest American manufacturers of microelectronic computer parts such as "INTEL" or "AMD".
Some Serbian companies also appear as exporters of parts for the aviation industry to Russia. It is about goods that have been under strict sanctions since the beginning of the aggression against Ukraine.
The mechanisms and routes through which shipments travel are different.
RFE/RL's data also indicate that part of the goods produced in the West were re-exported to Russia from the countries of East Asia through the paper of Serbian companies.
Because of this practice, goods whose import is prevented by EU and US sanctions can reach Russia.
On the other hand, in Russia, the recipients of the goods were companies that are under sanctions, even on the list of the US Office of Foreign Assets Control (OFAC) due to their participation in the supply chain of the Russian military industry.
Serbia does not violate its own rules because, although it is a candidate for membership, it has not agreed with the decisions on EU sanctions.
However, a country that does not respect sanctions decisions can be punished even by banning the import of modern technology produced in the West, according to the EU's decision on the 11th package of sanctions, which was adopted in June 2023.
Tens of thousands of different products were exported to Russia
"No one can circumvent the sanctions imposed by the EU on the Russian Federation through the territory of Serbia. Serbia reacts and sanctions such attempts," said Serbian President Aleksandar Vučić to European Enlargement Commissioner Oliver Varhelji on December 2, 2022.
Exactly in that period, in the last months of 2022, business not only increased, but the routes and mechanisms through which various goods arrived in Russia were also established, according to RSE research.
The export of goods which, according to customs markings, are now subject to US and EU sanctions has increased.
The customs documentation of the commercial databases of international trade "Import Genius" and "Sinoimex" does not identify the exact markings of the electronic components, and it is not possible to determine what happens to the goods after they arrive in Russia.
However, those goods are under sanctions because various types of electronic equipment have been identified in Russian military systems found on battlefields in Ukraine.
Serbian President Aleksandar Vučić, in his statement after the meeting with the European Commissioner, did not specify what kind of controls the state implemented in order to prevent the circumvention of sanctions.
Until the publication of this text, the Government of Serbia and the Ministry of Internal and Foreign Trade did not respond to RSE's questions about the manner in which control is carried out, nor whether anyone has been punished for possibly circumventing sanctions.
Serbian Customs, which has data on exported or imported goods, does not provide the public with documentation on the exports of individual companies, with the explanation that this is to protect the company's business secrets.
However, by analyzing the data of the "ImportGenius" and "Sinoimex" databases, RFE established that since the beginning of the invasion of Ukraine, thousands of different products exported by Serbian companies have been cleared by customs in Russia.
Firms unknown to the public were most often involved in this trade.
From the sale of tractor parts to the export of electronics
One of the companies that increased revenues is the company "Kominvex", which operates from a residential building in Belgrade's Rakovica.
The company "Kominvex" was founded in 2005. Until last year, its activity was wholesale of parts and equipment for motor vehicles. The company's website still offers the sale of lasers and alternators for trucks and commercial vehicles.
"We especially emphasize that our tractor program is very recognizable on the domestic market," the company's website states.
According to RSE research, the tractor business did not produce losses.
Data from the company's financial reports published on the website of the Serbian Business Register Agency (APR) show a profit of $67 in 2018. During 2021, the profit was about $1.600.
Everything changes in 2022. Then "Kominvex", after paying all obligations and taxes, had a net profit of 1,5 million dollars, i.e. a thousand times more in just one year.
APR data show that revenues from the sale of goods have increased almost a thousand times.
"Kominvex" changed its activity in November 2022 and registered for wholesale trade in electronic and telecommunication parts and equipment.
According to APR data, in 2022 it had one employee.
The owner and director of the company since its foundation is Marko Svorcan.
According to publicly available data, from April 2022 to May 2023, Svorcan was a director in two companies that were founded at the same address where "Kominvex" was registered.
The owners of those two companies, Orion and Mercury, were two Russian citizens. Maria Zakharova was registered as the owner of one, and Oleg Gruden as the owner of the other.
Both companies had almost no turnover, and in May 2023 they were sold.
Marko Svorcan, who still runs the company "Kominvex" today, answered RFE's call, but refused to provide any explanation about his business. RSE found more details in the international trade databases "ImportGenius" and "Sinoimex".
Data from these databases show that from March 2022 to mid-2023, Kominvex exported to Russia, among other things, microchips containing complex electronic components, processors, digital cable communication systems, mobile phones, light LEDs, cartridges, printers...
A large number of these products are under strict US and EU sanctions due to microchips, circuit boards and other sophisticated equipment being incorporated into Russia's modern weapons.
RSE analyzed more than 6.000 transactions that "Kominvex" as an exporter had with Russia from the end of March 2022 to the end of July 2023.
The analysis showed that "Cominvex" exported goods worth 143,9 million dollars, and as much as 54,3 million dollars worth of goods were so-called dual-purpose goods and, according to customs markings, are under EU sanctions.
Russian companies that are under US sanctions are among the buyers of goods
The largest shipments of these products in Russia were received by two companies "Bitteria" and "Velestor", according to data from the "Sinoimex" database.
"The quality of the product is guaranteed both by the company itself and by the manufacturer," it is stated on the website of the company "Bitteria".
"Bitteria", a Russian company, has been on the US sanctions list since September 14, 2023, when 100 other businesses and individuals were added to OFAC's long list.
The US Treasury Department's Office of Foreign Assets Control said the measures were enacted to "weaken Russia's ability to wage war against Ukraine by targeting Russia's military supply chains and depriving it of equipment, technology and services it needs."
The company "Bitteria" from Moscow has been operating for six years. Its income in 2022 was 136 million dollars, according to the website of "Sparka", a database of business enterprises in Russia.
The second company to which the so-called dual-use goods most often went, "Velestor", has been operating for two years, and its headquarters are in St. Petersburg.
None of the Russian companies answered RSE's questions about how they entered into business with companies from Serbia.
How do American goods reach Russian customers?
Research by RSE showed that in a large number of cases, the Serbian company "Kominvex" delivered to Russia electronic components of American manufacturers, including "INTEL", "AMD" and "HP".
The company "INTEL" is one of the world's largest manufacturers of semiconductors, which are used to make chips, and it has announced on several occasions that it takes care that products under sanctions do not reach customers in Russia.
Out of the 15 most valuable shipments of goods under sanctions, where the recipient was the Russian company "Bitteria", as many as 13 are products of "INTEL".
Through customs data from the "ImportGenius" database, where it is possible to see where the goods were sent to Russia, RSE investigated the routes by which the goods ended up in that country.
Customs data show that "Kominvex" is an exporter of goods to Russia, and the countries from which the products are shipped are mostly Malaysia, Vietnam and China.
These three countries did not impose sanctions on Russia, but "INTEL" has its factories in Malaysia and Vietnam.
Transport and logistics in a large number of cases is performed by "ATC Group", a cargo airline company that states on its Linkedin profile that it is "the leader in the transport of goods to Russia".
The company "INTEL" told RSE that it "does not support or tolerate" the use of its products "for the violation of human rights."
"When we learn that there is concern that INTEL products are being used by a business partner in connection with the abuse of human rights, we will limit or terminate business cooperation with the third party," the company stated in a written response to RSE.
Maximilian Hess, an associate at the Philadelphia-based International Institute for Strategic Studies, who researches ways to circumvent sanctions, told RFE/RL that data on the sale of American goods in Russia show failures at multiple levels.
"Both producers and exporters in, say, Malaysia have an obligation to ensure that their goods are not found in countries under sanctions. This is also the obligation of buyers, who in this case are Serbian companies. This is a clear violation of American sanctions," said Hess. for RSE.
He added that it cannot be said that "responsibility lies only with Serbian companies and institutions", but that there is a possibility that the American administration will recognize them "as those who are regularly involved in such activities" and sanction them.
The EU, the US and Japan have sanctioned 45 types of goods that make up multiple types of dual-use and advanced technology items.
In August 2022, the Royal United Services Institute, a British organization, published a publication on how this equipment was used in specific cases of the production of various weapons.
Thus, the products of the American companies "Mikrochip technology", "Texas industries", "Analog Devices" were also found in the Russian drone Orlan-10...
"Kominvex" is not the only company from Serbia for which data on trade with Russia can be found in the "Sinoimex" database after the beginning of the invasion of Ukraine.
"Trade, all goods are normal"
RFE/RL has identified another firm that exports goods under sanctions to Russia and was one of the suppliers of Russia's "Bitterie", a firm on the OFAC list.
It is about the company "Soha Info" from Novi Banovac, a small town about 30 kilometers from Belgrade. The company is located in a neighborhood of family houses and at the same address where the fitness club has been registered for five years.
According to the customs data of the "Sinoimex" database, "Soha Info" exported goods worth 2022 million dollars to Russia from October 2023 to the end of July 18.
Among these shipments are electronics that, according to customs labels, have been placed on the list of 'high-risk' and are subject to sanctions, and these are products worth 6,3 million dollars. And in the case of this company, the goods went through Vietnam, China and Malaysia.
Besides "Bitterie", Russian companies that are exporters in Russia are "ProTechMarket" from Moscow and "Imkotreid" from St. Petersburg. Both of these companies are registered for electronics trade, they have been working for only three years.
The Serbian company "Soha Info" was founded after the beginning of the invasion in June 2022, and according to the financial reports from APR, in just six months, it achieved turnover from the sale of goods in the amount of 6,1 million dollars.
The owner is Dragan Dragaš from Banovac, who is also a representative of the fitness club at the same address. Dragaš answered the call of RSE and said that he would not talk about his business with Russian companies because he "doesn't want someone to hack his scheme". When asked what kind of scheme was in question, he briefly said, "trade, all the goods are normal, they are not even subject to sanctions" and ended the conversation.
Trade in fruits and vegetables as a cover for circumventing sanctions
Two months ago, the Serbian public learned that there is a problematic export of goods under sanctions carried out by another Serbian company, "Goodforwarding doo" from Belgrade.
RSE's research showed that the company "Goodforwarding" from Belgrade exported to Russia this year and in 2022 static converters that convert alternating current into direct current, electronic integrated circuits and photosensitive semiconductor devices.
These are products identified by the European Commission services as dual-use goods and advanced technology products used in Russian military systems at the front in Ukraine.
The company "GoodForwarding" was registered in June 2022 at an address in a shopping center in New Belgrade.
Russian citizen Alexey Moskovkin from Omsk in Russia is listed as the director and owner of the company in the official register of Serbia.
There is almost no publicly available information about him. RSE was unable to find his contact even according to the place of residence that can be seen in the passport he used when registering the company in the APR.
RSE contacted the company two months ago through the e-mail from which it was registered in APR, and a person who introduced himself as Juan Pereiro Radriges answered.
He denied that "GoodForwarding" is engaged in the export of dual-purpose goods to Russia.
"GoodForwarding is open for importing bananas to the Russian Federation. Unfortunately, the bank did not allow the company to make payments in dollars and euros, so the company could not carry out any activity. Someone is using the company's data to import sanctioned goods," she said in a written statement. to the answer of a person who introduced himself as Rodrigues.
When asked by RSE what function he has in the company, Radriges introduced himself as a "shareholder".
RFE/RL tried to contact him again for further clarification, but Rodrigues did not respond to emails.
Although it claims that there is no turnover, the international trade database "Sinoimex" shows that the company cleared 2023 different shipments to Russia in the period from its formation to mid-119, and the value of the goods was close to 300 thousand dollars.
For all shipments, the end user in Russia is the company "Petersnab".
"Petersnab" was registered in January 2022, and the company's headquarters is in St. Petersburg, according to data from the "Spark" database on the company's operations in Russia.
Airplane parts from a house in the Belgrade neighborhood of Zvezdara
Although the attention of the EU and the USA has been focused on electronics that can be used in the military industry in recent months, the export of aircraft parts to Russia is also a potential risk in violating sanctions.
Sanctions for the aviation industry are one of the first that the EU and the US imposed on Russia after the start of the aggression against Ukraine.
In February 2022, the EU first refused access to European airports for Russian carriers of all types and banned them from flying over the Union's airspace.
Part of this type of sanctions is the ban on the export of products and technology from the aviation and space industry to Russia.
These sanctions mean that Russian airlines cannot purchase aircraft, spare parts or equipment for their fleet, nor carry out necessary repairs or technical inspections.
Three-quarters of Russia's commercial aircraft fleet is manufactured in the EU, the US or Canada, and the sanctions aim to ground a significant part of Russia's civilian fleet, even for domestic flights.
However, according to RSE's analysis, aircraft equipment and parts are exported through the company "Sprocure" from Belgrade.
This company was founded in August 2022, six months after the invasion of Ukraine. The registered activity in APR is "mediation in the sale of various products".
Serbian citizen Zineta Mehmedi is registered as director and owner.
The "Sprocure" website states that they are an international distributor of parts for the aerospace industry, with plans to be a repair and transportation management company with logistics and forwarding services.
"Our team has dozens of years of experience in the industry," the site says, and offers "very fast delivery of goods."
The APR shows that "Sprocure" had no employees in 2022.
The company is registered in the Belgrade neighborhood of Zvezdara, and there is a residential house at that address.
The shutters are down, and in the yard you can see an auxiliary building that does not match the size of the aircraft parts warehouse.
However, financial reports from APR show that in the first five months of business in 2022 alone, the firm had $1,7 million in sales revenue.
According to data from the "Sinoimex" database, during 2022, the company exported to Russia goods worth about one million dollars, and by the middle of 2023, slightly more than 230 thousand euros.
Of the exported products on the list, almost all are used in the aviation industry.
The owner of the company did not respond to RSE's inquiries about the business, which were sent by e-mail from the APR register.
When a call was made to a fixed phone number registered with the company, a person answered who said that the company's owners, Zineti Mehmedi, would pass on the questions to RSE.
The answers did not reach the publication of this text.
The company exported oil for the engines of passenger planes, tires used for these planes, sound or visual signaling devices, accumulators, batteries.
Parts for Boeing and Airbus arrived in Russia
According to the product description, it was mostly about parts for the "Erbas" and "Boeing" airplane models.
"Sprocure" exported the largest amount of goods to the Russian company "Kras Logistic".
"Kras Logistic" was registered in Moscow in 2012, according to data from the "Spark" database.
They are registered for transport support services, and on their website it can be seen that they offer land, water and air transport.
In November 2022, this company received financial support from the Ministry of Economic Development of Russia, according to an official document available in the "Spark" registry.
Apart from the company "Kras Logistic", the Serbian company "Sprocure" achieved the highest turnover with the Russian low-budget airlines "Pobeda" and "Smartavia".
Of these companies, only Smartavia responded to RFE's inquiries.
"Smartavia airline has no business relations with companies in Serbia and so far we have not operated flights to Serbia", the company stated briefly.
According to international trade registers, "Sprocure" delivered 90 percent of goods for the Russian market from the USA, worth as much as 900 thousand dollars.
Other parts came from France, Germany and the Netherlands, according to data from the "Sinoimex" and "ImportGenius" databases on the places from which the equipment was sent.
In May 2023, the USA sanctioned one of the cases of attempted trade, i.e. the export of aircraft parts to Russia.
Two Russian citizens, Oleg Patsuly and Vasiliy Besedin, residing in Florida, were arrested and charged with crimes punishable by up to 20 years in prison.
According to the announcement of the US Department of Commerce, the two Russians were in communication with representatives of the Russian airlines "Smartavia", "Rossiya" and "Pobeda" in order to acquire parts and components for aircraft of American origin.
According to reports, this was an attempt to circumvent sanctions because two Russian nationals claimed that the end user was a customer in Turkey, not Russia.
While proceedings are being initiated in America due to the trade in aviation parts, the data indicate suspicions that another Serbian company could be involved in the supply of Russian airlines.
Equipment for the Russian squadron from the Belgrade airport address
"Avio chem" was founded in December 2014 under the original name "Thoms aviation Adriatic doo Beograd", and was founded by Slovenian citizen Luci Aleš.
Since May 2020, the company has been registered at the address of the Belgrade airport "Nikola Tesla".
"Avio chem" is registered for repair and maintenance of aircraft and spacecraft, while other activities of the branches are cleaning of buildings and equipment, as well as rental and leasing of cars and light motor vehicles, according to APR data.
According to the official financial reports, in 2022 the company had a revenue of 3,5 million dollars, which is more compared to the total earnings they made in the previous four years.
The value of goods exported to Russia from November 2022 to July 2023 was about 3,1 million dollars.
The owner of the company "Avio chem" Aleš Luci responded to RSE's invitation and requested that the questions be sent to him by email. Although he repeatedly promised to answer and despite more calls from RSE, the answers did not arrive.
Parts for airlines that have contracts with Russian institutions
Almost the entire export of the company "Avio chem" ended, according to data from the Sinomix database, with two related airlines "Siberia Airlines" and "S7 engineering".
We are talking about companies close to the regime of Russian President Vladimir Putin
The company "Siberia Airlines" was registered in 1994 with headquarters in the Novosibirsk region, according to the data of the "Spark" database.
The general director is Klebanov Vadim Anatolevich. Both the company and the CEO are under sanctions from Ukraine.
In the last year and a half, they had more than 100 contracts with Russian institutions, it can be seen in the Spark database.
"S7 Inženjering" is a daughter company of "Siberia Airlines". This company, among others, has signed contracts with the Russian state institution "Special Aviation Squadron Russia, Administration for the Affairs of the President of the Russian Federation".
Representatives of these airlines did not respond to RSE's inquiries.
Tightening of sanctions and stronger control
In June 2023, the European Union adopted a new package of sanctions against Russia after an "increase in a very unusual flow of trade through the EU and some third countries" was observed, European Commission representatives explained.
Special emphasis is placed on preventing the circumvention of EU rules.
The European Union's special envoy for sanctions enforcement, David O'Sullivan, said on October 23 of this year that the EU has taken a more proactive stance when it comes to checking sanctions circumvention, but that the process will continue.
"Lately, our goal is to identify bad players in third countries (that have not imposed sanctions). We are still taking small steps, but our goal is to work to identify companies that are actively working to circumvent sanctions, in order to publish lists about them ", O'Sullivan said at the Atlantic Council roundtable.
RFE/RL sent a letter to the Bureau of Industry and Security of the US Department of Commerce, which controls the trade in American products, but by the time of publication of this text, no answer had been received to the question of how American goods are still arriving in Russia.
Tightening sanctions changed brands and routes
Research by RFE/RL showed that after the tightening of sanctions, especially in the USA at the beginning of 2023, the goods and the route through which they arrive in Russia have not remained completely the same.
RSE investigated what changes took place on the basis of more than six thousand transactions of the Serbian company "Kominvex".
Among the "Kominvex" shipments delivered to the Russian company "Bitteria" since March 2023, the products of the Israeli-American company "Check Point" were transported, the customs database shows.
The technology company says on its website that it is a leading provider of cybersecurity solutions to corporate enterprises and governments around the world.
The international office is in Tel Aviv, Israel, while the main US office is in San Carlos, California.
Among the 25 shipments to Russia were, according to the customs label, electronic modules for servers and computers, as well as accessories for telecommunications equipment that were recently placed under EU and US sanctions.
These goods were not exported directly from Israel or the USA either, but were shipped to Russia from Taiwan, according to data from the "Sinoimex" database.
Taiwan is one of the few countries in Southeast Asia that has imposed sanctions on Russia.
As told to RSE by the Ministry of Economy of Taiwan, this country has "implemented a series of export control measures that are aligned with those applied by the USA, the EU and other similarly oriented allies".
The state, they say, is constantly expanding the list of high-tech goods for which exporters must apply for an export permit. The Ministry continues to cooperate with industries "in order to prevent possible violations of the rules", according to a written response to RSE.
On the other hand, the company "Check Point" told RSE that "it is impossible that something illegal is happening".
They also state that they carry out strict controls "so that there is no doubt that the sanctions are fully respected".
"Before processing any business transaction, Check Point thoroughly checks each entity interested in doing business with us," the company's response states.
In the following, RSE submitted data recorded by databases on international trade, after which "Check Point" announced that they had conducted a "detailed internal investigation" and that they do not have a partner or distributor in Serbia under the name "Kominvex". According to their claims, these transactions do not match their trade documentation.
However, as they state, their distributor in Russia cooperates with "Kominvex" as a supplier in the supply chain, and they add that it is not dealing with end users.
"We have collected official letters from the Russian distributor and from Kominvex, which guarantee that all business is carried out in full compliance with Check Point's policies and rules," the company said.
Institutions in Serbia without answers
Until the publication of this text, representatives of institutions in Serbia did not respond to RSE's questions about how the state will react.
"Serbia is not and will not be a platform for circumventing the sanctions imposed by the European Union against Russia," announced the cabinet of Serbian Prime Minister Ana Brnabić on May 10 after the visit of EU sanctions enforcement envoy David O'Sullivan.
Serbian President Aleksandar Vučić said after the talks that Serbia "as a credible partner, will not leave room to be used for illegal actions, which would enable third countries to avoid the regime of EU restrictive measures".
However, the state's reaction was absent even after the US put the Serbian company "MCI Trading" from Belgrade on the list of sanctions on July 20 for providing technological support to the Russian invasion of Ukraine.
Now that they have been identified, these companies should be held accountable, said Maximilian Hess from the International Institute for Strategic Studies in Philadelphia, commenting on the RSE research.
"The export of that technology to Russia is prohibited because it is used for the production of Russian weapons and then for attacks on innocent Ukrainian citizens. Participating in this is direct support for Russian aggression. Serbia has a responsibility to ensure that its companies comply with international sanctions, to devise regulations and prevent things like this," Hess said.
He added that he expects a reaction from the USA.
Since the beginning of the Russian invasion of Ukraine, Serbia has faced harsh criticism from the West for its refusal to join the sanctions against Russia as a candidate country for EU membership.
Databases used for research
In addition to public databases, RSE used documentation collected under the Law on Information Availability for research.
Customs data was analyzed using two commercial databases with international trade details, "ImportGenius" and "Sinoimex". "ImportGenius" contains complete data on international trade for 18 countries, including the USA, India, Russia and most Latin American countries. "Sinoimex" is a customs database managed by the Chinese company Dalian Infobank.
As data sources, they list information that they collect in different ways from the customs of a large number of countries. Data on Serbian companies were collected from several databases of the Agency for Business Registers.
Russian companies were analyzed on the basis of the international commercial economic database "Spark".
Bonus video:
