Procurement in the modern era is no longer simply about value for money, compliance, or meeting deadlines. It has become inextricably linked with foreign policy, geopolitics, and ethics. As governments impose sanctions and trade restrictions in response to global conflicts and human rights abuses, procurement professionals are increasingly expected to act as frontline enforcers of these international rules, all while maintaining operational efficiency and legal compliance.
A Shifting Global Landscape
The last decade has seen a surge in international sanctions, including those imposed by the European Union, the United Kingdom, and the United States. The EU’s Regulation (EU) 833/2014, initially introduced in response to the annexation of Crimea, has expanded significantly following Russia’s full-scale invasion of Ukraine in 2022. It restricts trade with Russian entities and bans contracts with state-controlled companies.
In the UK, the Sanctions and Anti-Money Laundering Act 2018 empowers the government to apply sanctions independently post-Brexit. Meanwhile, Ireland, through its obligations as an EU member state, implements the same sanctions, enforced by the Department of Foreign Affairs’ Sanctions Secretariat.
This increasingly complex legal environment means procurement officers are not just purchasing goods and services, they are conducting legal risk assessments, ethical reviews, and sometimes geopolitical triage.
The Challenge of Hidden Exposure
The difficulty with sanctions lies in their enforcement. Many sanctioned entities operate through subsidiaries, shell companies, or friendly intermediaries based in countries not party to the sanctions. As a result, a seemingly innocuous contract with a UK-registered supplier might still violate regulations if that supplier sources components from a blacklisted entity.
A practical example: a local council in Ireland procures surveillance cameras for security purposes. The contract is awarded to a European distributor, but the components originate from a Chinese firm sanctioned under US or EU law for alleged human rights abuses in Xinjiang. While technically not illegal under Irish law (unless explicitly listed), the reputational and ethical risks are profound.
Dual-Use Goods: The Procurement Grey Zone
Dual-use items, goods with both civilian and military applications, pose a particular challenge. Regulation (EU) 2021/821 governs the control of such exports, but many contracting authorities lack the tools or expertise to assess the end-use of these items.
Scientific equipment, drones, encryption technology, and even chemicals can fall into this category. Procurement teams working in research-intensive sectors, defence-adjacent services, or international development must be particularly vigilant.
ESG and the Ethical Imperative
As ESG (Environmental, Social, and Governance) frameworks become more embedded in procurement policy, buyers are being asked to go beyond what is legal, and consider what is right. But this shift creates significant challenges:
How do you verify a supplier’s claims about ethical sourcing?
Can procurement exclude suppliers on moral grounds alone without breaching procurement law?
Who bears responsibility if a supplier turns out to be linked to human rights abuses indirectly?
The EU’s proposed Corporate Sustainability Due Diligence Directive (CSDDD), once enacted, may provide a legal foundation for procurement officers to exclude unethical suppliers based on supply chain risk, not just price or technical merit.
Ireland: Decentralised, Yet Active
In Ireland, the burden of sanctions enforcement lies with each contracting authority. The Department of Foreign Affairs provides lists, updates, and support through the Sanctions Secretariat, but there is no centralised tool for live supplier checks. Some local authorities rely on manual vetting, while others purchase access to tools like LexisNexis or Dow Jones Risk & Compliance.
Without consistent enforcement or shared infrastructure, the risk of accidental non-compliance grows, particularly for SMEs or regional authorities with limited capacity.
Building Resilient Procurement Functions
To address these challenges, procurement teams are beginning to adopt new practices:
- Geopolitical risk training for procurement officers, often via third-party certification bodies.
- Real-time vetting software that checks suppliers against updated sanctions and watch lists.
- Contractual clauses requiring full supply chain transparency.
- Ethical procurement policies, drafted in tandem with legal and compliance departments.
While not yet standardised, these measures reflect a growing recognition that procurement is a strategic, not merely administrative, function.
Between Law and Conscience
As the lines between commercial activity and geopolitical allegiance blur, public procurement must evolve. Buyers are no longer just stewards of taxpayer money, they are moral actors on the global stage. Whether sourcing medical devices, security infrastructure, or basic office supplies, every contract carries the weight of international politics.
Procurement professionals must be equipped with not just the tools, but also the judgment, to navigate this minefield. Because in the grey zone between legality and morality, the real power lies in discretion.
Sources:
EU Tourism in 2024: Key Updates and Emerging Trends – European Union
Fáilte Ireland Welcomes New Tourism Policy Framework – Failte Ireland
Unpacking Business Travel in Asia – ATPI
