Insights

ELEVIEW CASE STUDY:
SHIPPING METHODOLOGY AND SANCTIONS EVASION
 

On November 4th, 2024, the US Department of Justice charged Virginia-based freight forwarders Oleg Nayandin and Vitaliy Borisenko with conspiracy to violate the Export Control Reform Act by circumventing export restrictions on technology sent to Russia following the invasion of Ukraine. Nayandin and Borisenko operated a freight consolidation and forwarding company, Eleview International Inc., based in Chantilly, VA, which transshipped technology to Russia via Turkey, Finland, and Kazakhstan, falsely claiming end users based in these locations.

Artemis Research undertook a case study of one of Eleview’s purchases in order to better understand the methodology of illicit freight forwarding. Using publicly available sea cargo and business data, we identified the logistics route from the manufacturer to Eleview’s control. We then used information from the US Customs Bureau to assess the most probable route of this shipment on to Russia.

Known Route from China to the United States:

Manufacturer and Equipment: Using publicly available sea cargo data, we identified a purchase made by Eleview for an item labeled “DWS Machine SND-DWS” with a manufacturer listed as “Senad Robot (Shanghai)” in 2022. We identified this as an automated logistics system called a dynamic weighing and sorting machine—Chinese-manufactured intelligent logistics technology, which measures, weighs, scans, and sorts goods automatically. There was no indication of the specific end use or user in these documents. 

Carrier: The DWS machine was shipped to Eleview in four parcels from the Port of Shanghai on an unspecified date on the Panamanian-flagged cargo vessel One Hawk, using the Shenzhen-based carrier, We Can International Logistics. (Note: We assess use of this carrier is not an indicator of illicit shipments, given the vessel made 67 port calls at six different U.S. ports Between September 2020 and November 2024, carrying a range of commodities.)

Consignee: The four parcels arrived in the Port of New York on April 13th, 2022. Eleview was listed as both the consignee and the party to be notified, meaning they would make arrangements to retrieve the shipment from the carrier and deliver it to its final destination. Given Eleview’s activity described in the DOJ press release, it is likely they had the item transported to their facility in Chantilly and then relabeled the item for shipment via one of its three main routes—Turkey, Finland, or Kazakhstan.

Assessed Route from the US to Russia:

The DOJ indicates Eleview would repackage goods and ship goods from their warehouse in Chantilly to Russia via Turkey, Finland, or Kazakhstan. Therefore, we sought to determine the specific route for this item. By cross-referencing alternate sources, we determined it was likely shipped from Dulles Airport to Russia via Kazakhstan. We make this assessment based on a review of shipments of this type identified in export data from the US Census Bureau.

US Census data revealed a shipment of four items matching the description sent to Kazakstan by an unspecified shipper, which we assess is likely the Eleview package. We searched US census data for all exports in 2022 matching its description – specifically those with the HTS code 8423.20.0000, which is a number designating “scales for continuous weighing of goods on conveyor.” We identified a total of four items of this classification shipped to Kazakhstan worth a total of $7020 via air freight—the approximate value of the DWS machine—and none to either Finland or Turkey. We judge these four items make up one larger piece of equipment, and the number of parcels of the shipment matches the four parcels sent by Senad Robot to Eleview.

Therefore, it is likely Eleview purchased the equipment from China, and had it shipped to its facility in Chantilly, VA, then repackaged and shipped the DWS machine out of the nearby Dulles International Airport to Kazakhstan where it was likely transshipped on to Russia.

Epilogue:

This case study illustrates how technology is at risk of diversion, putting companies at risk of violating sanctions without their knowledge. The right research and rigor can help identify red flags in the shipping process—such as the circuitous shipping route identified illustrated by this shipment—protecting intellectual property from diversion.