World ECR | UK releases guidance on anti-Russia sanctions

The British government has issued detailed guidance for companies to combat Russia’s efforts to circumvent sanctions through a network of third-country procurement, warning that Moscow continues to purchase Western military and dual-use goods despite trade restrictions.

The U.S. Department of Commerce and Trade stated in guidance issued on January 7 that “Russia will go to great lengths to circumvent sanctions and continue to procure Western military, dual-use and other critical goods, including off-battlefield technology, through third countries.”

The document states that 14 countries, including China, India, Turkey and several Central Asian countries, require “enhanced due diligence” on certain export products, while noting that these jurisdictions are “taking steps to reduce” the flow of sensitive goods. Russia.

Major high-risk projects include integrated circuits, electronic components, manufacturing equipment, industrial machinery, aerospace instruments and automotive parts.

The guidance warns that Russian procurement networks often use “deceptive tactics” such as front companies, indirect shipping routes and falsified end-use documents to circumvent sanctions.

The government has also published template language for “no re-export to Russia” clauses in contracts, although this will remain optional for UK exporters, unlike the EU where such clauses are mandatory for certain goods.

The guidance states that “reducing Russia’s ability to prolong the war in Ukraine remains in the interests of the security and economic prosperity of all UK businesses and individuals” and urges businesses to report suspected breaches to the authorities.