Weak Sanctions Enforcement Is Fueling China’s ‘Polar Silk Road’

To be effective, American sanctions must be enforced wherever they apply — including in the High North. Early in September, two U.S.-sanctioned vessels left China carrying the last two power generation modules needed to finish a major section of Arctic LNG 2, a heavily sanctioned energy project that Russia intends to become a major hub for the country’s energy exports. 

While it remains unclear when the modules may arrive at Arctic LNG 2, the voyage reflects a negative and inexplicable shift in how the United States is enforcing sanctions against Russia’s still-developing Arctic energy infrastructure. Furthermore, the lack of enforcement risks bolstering efforts by China to invest in — and secure access to — Russia’s increasingly strategic Arctic ports and energy infrastructure.

China Holds the Key to Russia’s Arctic Energy Buildout

In November 2023, then-Assistant Secretary of State for Energy Resources Geoffrey Pyatt told Congress that Washington aimed to “kill” Arctic LNG 2. In July 2024, a Chinese-flagged vessel reversed course with two 14,000-ton modules originally intended for use in the project. Washington then sanctioned the Chinese fabrication yard that constructed the modules, leading the yard’s parent company, Wison New Energies, to sell the yard to a Chinese state-owned company controlled by the Nantong municipal government. However, with the Trump administration’s apparent shift toward non-enforcement in the Arctic, the modules reached Arctic LNG 2 in July 2026. 

China is the top buyer of Russia’s sanctioned Arctic-derived LNG, with its Beihai terminal receiving 41 Arctic LNG 2 cargoes totaling 2.6 million tons between August 2025 and June 2026. Beijing is investing in additional Arctic LNG import capacity with the buildout of the state-run PipeChina’s Longkou LNG terminal, just as Russia is seeking investment for a $400 billion program aimed at expanding the Russian Arctic transportation and heavy industry sectors. 

Beijing’s Arctic Foothold Expands

China’s support for Arctic LNG 2 advances its 2018 Arctic policy, which calls for a “Polar Silk Road” of shipping routes and supporting infrastructure. The project deepens Chinese access to Russian ports and experience operating along the Northern Sea Route. These commercial ties could eventually support Chinese naval and coast guard operations. Beijing’s civilian activities also carry military applications. Chinese research ships have mapped the seabed north and west of Alaska, collecting data that the U.S. Office of Naval Intelligence warns can aid submarine operations and seabed weapons placement. Although commercial, Arctic LNG 2 could support a more persistent Chinese presence near NATO’s northern flank.

Improve Sanctions Enforcement, Allied Surveillance Capabilities

The recently enacted Lindsey O. Graham Sanctioning Russia Act requires the president to review and potentially sanction principal shareholders with controlling or majority stakes in Russia’s Arctic energy projects, including Yamal LNG and Arctic LNG 1, 2, and 3. Russia’s largest privately held natural gas company, Novatek, is the majority shareholder in each of these ventures, placing it squarely within the scope of these sanctions. The sanctions also reach foreign port owners and operators that service the vessels helping Russia evade sanctions, creating risk for Chinese logistics nodes linked to these voyages, such as the Beihai and Longkou terminals. The Trump administration should aggressively enforce these sanctions — and Congress should demand accountability if enforcement remains weak.

Under Arctic Sentry, NATO’s “enhanced vigilance activity” that coordinates military activities in the region, the alliance should combine daily commercial satellite imagery from its SINBAD surveillance program with vessel-tracking and ownership records. As capabilities mature, NATO should also incorporate data from Task Force X Arctic, which is testing connected sensors and uncrewed systems to support High North surveillance. Together, these tools could strengthen allies’ abilities to identify suspicious shipments, cargo transfers, and port activity, building a shared picture of Sino-Russian regional operations. Allied military forces should share findings with national sanctions authorities to support investigations and enforcement. The United States and Norway should increasingly lead these efforts — Washington with its sanctions capabilities and Norway with its location and experience monitoring Russian Arctic activity.

Max Meizlish is a research fellow for the Center on Economic and Financial Power (CEFP) at the Foundation for Defense of Democracies (FDD). Emmerson Overell is a project coordinator at the Center on Cyber and Technology Innovation (CCTI) at the Foundation for Defense of Democracies (FDD), where she researches threats to U.S. and allied security in the Arctic, space, and cyberspace. For more analysis from Max and Emma, please subscribe HERE. Follow FDD on X @FDD, @FDD_CEFP, and @FDD_CCTI. Follow Max on X @maxmeizlish. FDD is a Washington, DC-based, nonpartisan research institute focusing on national security and foreign policy.