Tech Supply Chains Under Scrutiny: Tesla, Amazon and Nokia Name Sanctioned Suppliers

Over 160 US companies – including Tesla, Amazon and Nokia – have named four sanctioned Russian and African gold refineries as potential suppliers in their conflict minerals reports. This is shown by an analysis from the Financial Times dated 3 September 2026. The affected companies emphasise that they cannot confirm whether these enterprises have actually supplied material to their supply chains.

Four sanctioned refineries in focus

The analysis refers to four companies: the Russian metallurgical firms Uralelectromed and Krastsvetmet, as well as African Gold Refinery in Uganda and Gasabo Gold Refinery in Rwanda. Both Russian companies were sanctioned by the US and UK in 2023, after the London Bullion Market Association (LBMA) had already suspended cooperation with all Russian mining and processing companies on 7 March 2022. In June 2022, the G7 introduced an embargo on gold imports from Russia.

African Gold Refinery was sanctioned by the US Treasury in March 2022. The agency accused the company of being part of a network around Belgian businessman Alain Goetz that moved illegally mined gold from the Democratic Republic of Congo – estimated at hundreds of millions of dollars annually – out of the country. The gold came from mining areas controlled by militias and was smuggled into international markets via Uganda and the United Arab Emirates. US authorities estimated that over 90 percent of Congolese gold is smuggled into neighbouring countries, depriving the country of tax revenues and financing armed groups.

Gasabo Gold Refinery followed in June 2026. The US Treasury accused the refinery of transporting at least 60 kilograms of gold worth several million dollars from M23-controlled areas of eastern Congo to it during the first months of 2026. M23 is an armed group operating in the east of the Democratic Republic of Congo.

What the companies state in their reports

Tesla named all four sanctioned companies in its reports and stated that it was unable to confirm their presence in its own supply chain. Amazon listed Krastsvetmet as a metallurgical and refining company that "possibly processed gold for products", but noted that "it cannot be confirmed whether this list is correct".

Nokia, whose reports also contain all four companies, stated that it has been requesting suppliers since 2020 not to use African Gold Refinery. Since 2024, the same applies to Uralelectromed and Krastsvetmet. Volkswagen listed all four companies and noted that the list "contains potential suppliers" and the company "cannot definitively confirm or exclude their involvement".

All affected companies deny direct business relationships with the sanctioned firms, but cannot rule out that their products reach them through multi-tiered supply chains.

Legal background: Conflict minerals reporting

The Dodd-Frank Act – a US law passed after the 2008 financial crisis – requires companies with securities traded on US exchanges to report on conflict minerals. These minerals include tantalum, tin, tungsten and gold. The United Nations notes that in certain regions competition for these resources leads to conflicts, corruption, environmental damage and human rights violations.

Naming in these reports documents potential entanglements in multi-tiered supply chains, not evidence of actual business relationships. The cases illustrate a fundamental compliance dilemma: major corporations cannot completely trace gold through every trader, refiner, component manufacturer and contractor in global supply chains.

Challenges in supply chain compliance

According to PwC Germany's assessment from June 2026, EU sanctions lists are updated quickly – often within days of political events. Manual screening is no longer reliable at this pace. The risk of indirect sanctions violations is particularly high for hardware components such as inverters, battery components and control electronics, whose supply chains often run through third countries with low transparency.

Compliance requirements tightened further in June 2026 when China imposed countermeasures against US sanctions: ten US companies were excluded from dual-use exports, and 46 US companies were banned from purchases by Chinese state entities. This increases complexity in approval processes and supply chain design.

With US sanctions lists – the so-called SDN List – market participants must distinguish between false positives and complex ownership structures, where identities are spread across multiple jurisdictions. This is particularly true for raw materials like gold, which can flow through both legal and illegal channels.