On January 7, 2024, the UK Office of Trade Sanctions Implementation (“OTSI”) issued guidance to enable UK exporters and manufacturers to better understand Russian efforts to evade sanctions. The guidance was issued specifically to help exporters and manufacturers identify Russian evasion practices and prevent their goods from becoming the target of circumvention. The guidance provides the following information:
- The types of goods at heightened risk of being diverted to Russia
- Red flag indicators of possible export control and sanctions evasion efforts
- Suggestions for enhancing due diligence procedures and implementing compliance best practices
- Additional resources, including screening tools, that help businesses manage risks and compliance obligations.
OTSI provides key circumvention data, including a Common High Priority List (CHPL) that the UK government developed with partners in the European Union, Japan and the United States. The guidance also contains a list of goods that are at higher risk of circumvention, which are often procured via third countries. A list of third countries that tend to re-export to Russia is also provided. OTSI encourages businesses to remain vigilant in their efforts to identify red flags and patterns that may indicate possible circumvention of UK sanctions, including the diversion of products to Russia by intermediaries. In order to ensure that compliance procedures and due diligence frameworks remain effective, OTSI also advises businesses to continuously monitor their sanctions risks and the methods used to assess their vulnerabilities as new sanctions are adopted and circumvention techniques change.
UK Government – Countering Russian sanctions evasions – guidance for exporters