Evaluating Norway’s Readiness in Risk Management Relating to Russia’s Northern Sea Route
Special Edition with Guest Student Authors from the Schar School of Policy and Government at George Mason University (https://traccc.gmu.edu/)
I have been honored to be an Adjunct Professor at GMU’s TraCCC (The Terrorism, Transnational Crime and Corruption Center) for several years. Many AML/Sanctions experts have joined me as guest lecturers as we work with graduate students either in or contemplating a career in our community. This past summer, in my International Money Laundering, Corruption, and Terrorism class the challenge was to educate and stay current with the plethora of changes occurring in the US and internationally.
The students were required to submit a final paper on a topic related to the vast areas covered in class, and I have selected several papers that I know will be of interest to many.
Chair, AML RightSource Advisory Board
As climate change transforms the Arctic, seafaring nations worldwide are reckoning with the burgeoning availability of new sea routes. One such route, the Northern Sea Route (“NSR”), shows significant potential to provide seasonal shortcuts between Europe and Asia, potentially saving ships 30% in time and costs by cutting through the Arctic Ocean (Elisee and Naumova 2021, 161–162). The NSR has attracted shipping activity since 2010, the first season to feature “international use of the NSR for commercial purposes” (Solski 2020, 384). Usage has continued to ramp up, with total shipping volume in 2021 sporting a reported fifteen-fold increase versus a decade prior (Humpert 2022).
There is, however, a catch for compliance-minded observers of the NSR: the route lies predominantly in Russian waters. While maps’ precise definitions of the route differ, they all depict the NSR stretching virtually from Norway to Alaska via the Arctic Ocean north of Russia (Arctic Portal 2022; Turunen 2019). Russia’s assertion of control over the NSR—paired with the nation’s well-documented crime and corruption risks—has the potential to facilitate bad actors’ exploitation of the route.
The NSR’s vulnerabilities are particularly relevant to Norway, Russia’s Arctic neighbor by land and sea. Maritime issues are overall relevant to Norway, whose merchant marine fleet size ranks only behind Russia and Malta among European and Central Asian countries (CIA n.d.). Though Norway is not currently among the NSR’s biggest users, evidence suggests that the route may yet become more important to Norway, since “the strategic geographical location of its ports on NSR makes Norway an important player” (Karamperidis and Valantasis-Kanellos 2022, 426).
As a nation with highly graded institutional capacity, Norway has the opportunity to develop early regional norms and combat illicit behavior in the Arctic and the NSR. To contextualize these opportunities, this paper will first discuss the financial crime risks connected to the rise of the Northern Sea Route. This risk profile, on which Russian behavior is a significant influence, includes sanctions avoidance, corruption, and organized crime. Next, this paper will review Norway’s relevant abilities, successes, and failures in managing risk related to the NSR and the overall Russo-Norwegian relationship. Given this context, this paper will introduce policy proposals and other best practices for Norwegian regulators and practitioners to consider.
Background: The Arctic, Russia, and the High Seas
The Arctic writ large is a source of both promise and governance issues for the Russian Federation. In its relatively early stage of economic development, Andreeva already notices corruption taking form in the region, with “private companies [...] focus[ing] exclusively on exploiting its rich natural resources to promote their own interests, over those of the Arctic, the country, and the people” (2019, 638). As one of the Arctic’s most significant opportunities for Russia, the Northern Sea Route presents significant financial crime risks deriving from shoddy norms and governance.
Russia’s Plans for the NSR: The Northern Sea Route presents Russia with a source of significant economic promise. As Hermann et al. discuss, the Arctic waterway holds significant shipping potential, particularly “given the geophysical, market potential, and connectivity factors at work in the region” (Hermann et al. 2022, 1). The Russian government has taken note, with Russian President Vladimir Putin in 2018 setting his government’s sights on a benchmark of 80 million tons of annual NSR shipments (Kruessmann 2021, 708). The route’s promise is not without qualification; Brigham asserts that “the Arctic Ocean will be partially or fully ice-covered for six to seven months through the century” (2021, 146), making for a riskier journey than an ice-free voyage. However, the Russian company Novatek still, as of 2023, reportedly plans to leverage its Russian Arctic LNG projects and “begin year-round eastbound navigation via the Northern Sea Route at the start of 2024” (Lee 2023).
To safeguard its share of the region’s maritime future, Russia has sought to exert significant control over the NSR. Brigham highlights three initiatives Russia has pursued to increase control over its northern maritime border:
- A 2017 law limiting certain natural resource loadings to “Russian-flag ships” (Brigham 2021, 152);
- Legislation in 2018 giving management authority over the NSR to Rosatom Corporation, Russia’s nuclear power agency (Brigham 2021, 152).; and
- A proposal to potentially “develop a state-owned (and controlled) container shipping system along the NSR [that] would use Russian-flag container ships escorted by nuclear and non-nuclear icebreakers” (Brigham 2021, 152).
Russia’s national focus on the NSR, paired with the tight control it has asserted, introduces significant risks. Observers of the NSR should home in on three specific threats along the NSR: sanctions avoidance, corruption, and organized crime.
Financial Crime Risk No. 1: Sanctions Avoidance - The geography and governance of the Northern Sea Route give Russia an option to avoid Western sanctions. Russia can trade through this novel waterway while decoupling from Europe-adjacent trade routes. In one example, recent sanctions from the European Union have prompted Russia to find new buyers for its crude oil in China and India; reaching these markets via the NSR—as opposed to the route through the Mediterranean Sea and the Suez Canal— “could shave as much as two weeks [...] off the voyage” (Lee 2023).
Russia’s NSR management structure also lends itself to sanctions violation risk. Rosatom, now the NSR’s manager, has reportedly “been working to supply the Russian arms industry with components” (Belton 2023). The governments of the United States (U.S. Department of State 2023) and United Kingdom (Cleverly 2023) have each sanctioned Rosatom-connected companies in the wake of Russia’s 2022 invasion of Ukraine. Such a system as the one introduced in the third initiative discussed by Brigham—which would put more NSR shipping into the hands of a state-owned enterprise (2021, 152)—could further integrate risky actors into the NSR transshipment process.
However, transshipment risks exist even without Russia owning every stage of the shipment process. According to Wood et al., “flags of convenience” have already shown significant involvement in the Arctic (Wood et al. 2021). The flag of convenience strategy consists of a vessel “register[ing] and sail[ing] under [the] flag” (Feldman 2022, 1) of a foreign country. Given that nations “vary substantially in their standards and enforcement levels” for maritime law (Id., 3), bad actors may seek registration within regimes with lax accountability structures. Feldman says that various sanction-avoiding behavior—including “disguising a vessel’s identification, falsifying cargo and vessel documents, disabling a vessel’s Automatic Identification System (AIS), and moving cargo from and to vessels at sea rather than in ports”—is “strongly related” to bad actors’ reliance on the flag of convenience practice (Id., 1). The Russian Arctic has already seen this risk proliferate; on the NSR, roughly a quarter of 2018 transit came from flags of convenience, such as Panama and the Bahamas (Wood et al. 2021).
Financial Crime Risk No. 2: Corruption - Corruption is a significant risk in the overall Russian economy. Russia ranks No. 137 of 180 countries on Transparency International’s 2022 Corruption Perception Index, with its score dropping for two consecutive years (Transparency International n.d. [A]). In 2019, FATF commented that Russia was aware that internal corruption contributed to “significant money laundering risks as a result of the proceeds of crimes committed within the country” (FATF 2019). Infrastructure projects are a particular source of corruption, with Andreeva highlighting “corrupt administrators of all ranks who hamper useful initiatives by transferring government funds toward nontargeted expenses” (Andreeva 2019, 639).
These corruption risks, especially when tied to infrastructure, extend to the Russian Arctic. Arctic development requires significant investment, and Moxorov et al. see corruption as a threat to “institutions of the rule of law and the stability of public life” in the Russian Arctic (2020, 2). Though these institutions may be necessary—or at least useful—for ensuring efficient use of Russia’s significant Arctic investments, Kruessmann observes that the country’s authorities “do not seem to be concerned, in particular, about corruption in the Arctic,” leaving standards to the relevant territories (2021, 700).
Specifically relevant to the NSR is the complex involvement of the People’s Republic of China in NSR development and the dueling corruption standards between Russia and China. China has invested in the region through its Polar Silk Road initiative, a tenet of which includes “China’s political will to develop and use Arctic shipping routes” including the NSR (Liu and Solski 2022, 856). The two superpowers could thus benefit from reaching an understanding about combating corruption in infrastructure and trade; however, Kruessman claims that any state effort along the Polar Silk Road “to combat corruption may be frustrated by deep-rooted expectations of corruption in the public sector” (Kruessmann 2021, 700).
Financial Crime Risk No. 3: Organized Crime - While existing literature does not yet dive as deeply into organized crime along the NSR, observers have identified multiple organized transnational crime risks, though not necessarily confined to just Russia’s portion of the Arctic. In 2009, the Arctic Foundation’s “Arctic Portal” published a post providing an overview of organized crime risks in the region. As with corruption, the sheer size of the needed infrastructure projects facilitates organized crime risk; in this case, the facilitator of rising crime was “considerable amounts of staff; often single men with a disposable income further increasing the role of the cash economy” (Arctic Portal 2009). The Arctic Portal claimed that organized crime syndicates had already infiltrated the region and were facilitating tracking, fraud, and violent crimes (Ibid.). Crime risk has persisted; Gricius in 2021 wrote that the emerging prevalence of the NSR, particularly in the context of complex international maritime law, could create governance problems. Such ambiguities could contribute to transnational crime, as “unknown ships also bring with them unknown purposes, of which many could be illegal fishing or even illicit trafficking” (Gricius 2021).
Research: Norway’s Institutional Capacity
Banking Russian business, including in the emerging Arctic and its Northern Sea Route, presents significant risk. As other countries and companies consider how the NSR fits into their economic futures, these risks posed by Russia will undoubtedly be obstacles to overcome.
One such country is Norway, which shares a land border with Russia on the coast of the Arctic Ocean and thus lies immediately to the West of the Russian NSR. Norway is thus far a minor destination for NSR users; while two NSR voyages ended in Norway in 2021, Russia and China led the pack with 33 and 30 voyages, respectively (Hermann et al. 2022, 2). The extent to which Norway will become a major maritime player in the Arctic is an evolving story. Before Russia’s 2022 invasion of Ukraine, Gunnarsson observed that Novatek was planning to shift LNG ship-to-ship transshipment out of Northern Norway and into Russia (7). However, Norway also is one of the original players in NSR cross-transit voyages not destined for a site within the Arctic, shipping iron ore to China through the passage in 2010 (Ibid.).
Businesses and bankers in Norway and abroad should thus be cognizant of Norway’s capabilities in regulating the nascent NSR. The below research gauges Norway’s capabilities in its financial crime mitigation, particularly in the context of its complex relationship with Russia.
Norway’s Strong (and Strengthening) Defenses: From an economy-wide perspective, Norway is an institutionally strong nation. The Basel Institute on Governance ranks Norway as No. 120 of 128 nations on its ranking of countries with the most money laundering or terrorist financing risk; this ranks far safer than Russia, which places at No. 58 (Basel Institute on Governance 2021). The Fund for Peace ranks it as the world’s most stable country in 2023 (Fund for Peace n.d.), and it places fourth of 180 nations on Transparency International’s 2022 Corruption Perception Index (Transparency International n.d. [B]).
Norway has also taken significant steps in the 21st Century to rectify gaps in its regulatory system. According to Haggerty, Norway has been a trailblazer in countering illicit finance, launching its “Task Force on the Development Impact of Illicit Financial Flows” in 2007 and backing the “Financial Transparency Coalition” in 2009 (2015). In 2015, the Norwegian Parliament voted to create a public corporate ownership registry to hinder bad actors’ ability to hide behind “anonymous companies” (Haggerty 2015). The Financial Action Task Force this year recognized Norway’s progress toward further addressing its deficiencies, highlighting that “Norway has adopted the new EU Regulation on information accompanying transfers of funds (TFR) which require financial institutions and intermediary institutions to maintain the beneficiary information in cross-border and domestic wire transfers where required” (FATF 2023, 3–5).
Norway’s good governance extends to the maritime space. Wood et al. in 2022 called Norway “one of the most transparent states in providing shipping registration data,” explicitly lauding its “easy access to all fees, documents, and requirements in a highly navigable website” (Wood et al. 2022).
Norway’s Russia Risks: Norway and Russia maintained a sizable economic relationship prior to Russia’s 2022 invasion of Ukraine. Russia has previously been a significant trade partner for Norway, ranking as the No. 12 originator of Norwegian imports in 2021 (OEC, n.d.). The neighbors have also collaborated on border issues, with Bhagwat and Rogachev writing that the nations strengthened relations in 2018 with a plan to implement “more than 20 joint projects and activities in areas such as transport and logistics, the arrangement of the state border, and the effective functioning of checkpoints” (Bhagwat and Rogachev 2023, 131).
Though Norway’s defenses against financial crimes are strong, its complex relationship with its neighbor facilitates both short- and long-term risks. As ACAMS has noted previously, Russia and other Nordic financial institutions are potentially susceptible to Russia’s risks, given their proximity to Russia’s borders (ACAMS 2021). In one significant example, investor and author Bill Browder showed that DNB ASA, a Norwegian lender, “helped transfer $533,000 in Russian cash through accounts in Estonia and Lithuania;” Norway’s economic crime-fighting authority, the National Authority for Investigation and Prosecution of Economic and Environmental Crime, had reportedly “investigated the transactions from 2007 to 2010 and decided not to pursue it further” (Bergman 2018). Additionally, Myhre et al. highlight that Russian media previously featured “official Russian arguments used to legitimise the annexation” of Crimea (2022). In the long term, this could increase the risk that more Norwegians become sympathetic to Russian causes and thus more open to facilitating licit or illicit cross-border exchanges.
Norway’s Maritime Risks: Maritime issues further accentuate Norway’s Russia-related risks a. Per Myhre et al., Russo-Norwegian relations on the high seas were once strong, with the countries collaborating on rescue, conservation, and Barents Sea border issues through 2010 (2022). However, even prior to Russia’s annexation of Crimea, Myhre et al. claim that Norway’s NATO involvement had already strained the nations’ friendship (Ibid.).
During Russia’s current conflict with Ukraine and amid Western reactions, Russia has used its Norwegian maritime border to dodge sanctions. Nilsen, a reporter for The Barents Observer, reported in January 2023 on illicit activity involving Russian fishing ships, which could only dock in specific Norwegian ports following an October 2022 decree. Per Nilsen, some Russian ships stayed “in Norwegian ports for weeks,” giving their crews inappropriate access to “shops selling electronics, like toy drones and other electronics now under EU sanctions” in the cities of Tromsø and Kirkenes (Nilsen, 2023). In a different scenario, Bhagwat and Rogachev claim that Norway’s restrictions did not affect fishing vessels on the Spitsbergen archipelago; the authors therefore perceive that Norway—despite sanctions—shows “a serious interest in continuing cooperation in areas particularly beneficial to the Norwegian government” (Bhagwat and Rogachev 2023, 132).
The economic potential of the Northern Sea Route could further tempt Norwegian actors to become more lax in their enforcement of Russia sanctions. Bhagwat and Rogachev, who in their 2023 article “Cooperation Between Russia and Norway: Strengthening Dialogue in the Arctic” appear sympathetic to Russia’s actions in Ukraine (130), specifically address the use of the Northern Sea Route as a potential source of rapprochement between the countries (132). The authors claim that even though “the official discourse notes that the NSR is not interesting to Norway,” the route will “inevitably attract foreign partners and investors” (Ibid.).
Analysis & Policy Recommendations
While strong overall, Norway’s financial regulatory apparatuses show some vulnerabilities concerning Russia and the Northern Sea Route. Norwegian actors in the government, banking, and business sectors should thus explore ways to safeguard against the potential for illicit activity at its Arctic borders. In the context of the three financial crime risks the NSR poses, this section will synthesize the previous research into Russian and Norwegian activity and weigh the pros and cons of various risk mitigation strategies.
Stronger Sanctions Controls: The sanctions sector presents significant risk in Russo-Norwegian finance, including on the NSR and in Norwegian waters. Russia’s management of the route involves the problematic Rosatom Corporation, and Russia can use the NSR to connect more easily with countries not part of Western sanction regimes. Ships using “flags of convenience” are already exploiting the NSR, which poses additional sanctions risk. In Norway, Russian ship crews have pursued sanctioned goods.
Perhaps the most significant policy Norway could consider is forcing ships that use its ports en route to Russia to “inconvenience” their flags. In other words, Norway could adopt, as Wood et al. call them, “Domestic Port State Controls” that could hold ships “accountable even if the flag of which it flies under is not holding it up to the same standards” (2021). Such an approach is controversial and is, according to Feldman, of disputable effectiveness. Feldman claims that there is not yet evidence that foreign-flagged ships have “an overall macro-level effect on the success rate of sanctions” (2022, 1–2). However, he concedes that some bodies, like the U.S. Treasury’s Office of Foreign Assets Control, have linked so-called open registries—which enable “deceptive maritime practices”—with sanctioned states’ ability to access sanctioned weapons and other goods (Ibid.).
Countering Corruption: While corruption is not a significant issue in Norway, its connections to Russia increase the chance that issues may arise. Non-governmental organizations have recognized Norway for its stability and lack of corruption. However, governance factors in Russia have fostered the likelihood of corruption in the Russian Arctic, including along the NSR.
Again, a potential policy solution—a “mandatory payment disclosure”—is controversial. Jiang notes that, in the transit trade business, commodity trading companies “build connections with foreign officials and politicians,” which facilitates “especially large” corruption risk (Jiang 2019). Kruessmann believes calls for such laws “will probably also fall on deaf ears,” since expecting Russian law enforcement to counter this issue aggressively is “probably futile” (Kruessmann 2021, 709). However, Norway and other Nordic nations could serve as buffers and set a high standard on the outskirts of the NSR. By strengthening disclosure laws that ensure Norwegian and partner businesses have to disclose payments made to commodity trading companies, Norwegian companies can counter corrupt trading companies’ kleptocratic swap deals (Jiang 2019).
Dismantling Criminal Networks: Risks of organized crime have emerged across the Arctic. Experts assess that the region’s still-developing norms and government leave room for trafficking, illegal fishing, and fraud risks. Norway and Russia have previously collaborated on regional issues, but international geopolitics have strained relations.
Given the transnational nature of much of this organized crime, Norway and its Western Arctic counterparties may need to explore ways to engage with Russia on regional governance while maintaining pressure on Russia elsewhere. Such collaboration has previously yielded results; following a 2003 meeting, the region’s Barents Council set up a task force involving Russia, Norway, Finland, and Sweden to counter human trafficking in the region (Regeringskansliet 2006). This partnership matured into the establishment of “Contact-points[...] in each country, both at ministerial level and regional and central level” and further “cross-border cooperation on the operational level in the region” (Ibid.). Wood et al. believe that Norway’s transparency in ship registration gives Norway a credible path to regional shipping governance leadership (2021). However, Norway would need to balance such collaboration with its security and foreign policy priorities of countering Russia. Indeed, Russia’s 2022 invasion of Ukraine complicated Arctic relations, starting with the seven other Arctic nations temporarily pausing participation in the multilateral Arctic Council shortly after the invasion (Office of the Spokesperson 2022).
Suspicious Activity Targeting: Financial institutions and other businesses can additionally develop methods for detecting and disrupting risky transactions relevant to Norway’s Arctic border. While increasing banks’ obligations to monitor transactions can push huge costs onto financial institutions (Robinson 2020), well-calibrated typologies could appropriately balance banks’ compliance and market-building obligations. Examples of potential red flags for banks to consider include:
- Regarding sanctions, given the aforementioned example of Russian sailors roaming freely in northern port cities, banks in Norway could treat with suspicion transactions or deposits in the cities of Tromsø and Kirkenes that involve Russian citizens. They could treat transactions that involve accounts whose previous transactions come from Russian shipping or fishing hubs with similar incredulity.
- Regarding corruption, Norwegian institutions could monitor transactions involving entities connected to major Russian commodity companies active in the Arctic, such as Novatek.
Caveats & Concluding Remarks
Norway’s robust institutional capacity empowers the Nordic nation to take aggressive actions like these to counter illicit activity along the Northern Sea Route. Notably, Norway’s NSR strategy need not limit itself to the financial crime scope of this paper. For example, Karamperidis and Valantasis-Kanellos describe an option for Norway to invest in a Northern Norway transshipment hub in the town of Kirkenes, which has received “considerable attention from Chinese companies looking to utilise the NSR” (2022, 445).
Also worth considering is that Norway is only part of the compliance picture; indeed, other nations like China, Denmark, Canada, and Finland were more frequent destinations for NSR voyages than Norway in 2021 (Hermann et al. 2022, 2). However, Norway has implementation advantages in its geographical proximity to the problem, comparatively large merchant marine fleet, and strong governance. Norway therefore faces a unique opportunity to combat illicit actions face-to-face, institutionalize better regional norms, and preserve the integrity of the NSR’s economic potential.
Carter Coudriet is a graduate student at George Mason University’s Schar School. This work constitutes the final paper assignment for the “International Money Laundering, Corruption, and Terrorism” course. The author’s work and opinion are his own and do not reflect the opinions or findings of the U.S. Department of Commerce, or any other government agency. Any errors are the author’s own.
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