G7 issues first joint guidance on Russia-related sanctions and export control evasion
The Group of Seven (‘G7’) countries have released their first-ever joint guidance for industry, aimed at ‘preventing evasion of the export controls and sanctions imposed on Russia,’ the US Bureau of State Department announced, 24 September.
The updated guidance outlines the following priority areas:
- Items that pose a heightened risk of being diverted to Russia;
- Red flag indicators of potential export control and/or sanctions evasion; and
- Best practices for industry to use to address these red flags and conduct enhanced due diligence.
‘The goal of the guidance is to protect common high priority list items from misappropriation, prevent reputational harm, and mitigate liability risk, all while supporting the continued success of coordinated export controls and sanctions,’ BIS said in a press release.
The guidance provides strategies for industries to identify and mitigate risks associated with export control violations. It emphasises the importance of due diligence and robust compliance programs to detect and prevent illicit activities.
According to BIS, ‘Industries are encouraged to implement enhanced screening processes and improve information sharing among G7 members.’
The guidance document includes:
1. A list of items which pose a heightened risk of being diverted to Russia,
2. Updated red flag indicators of potential export control and/or sanctions evasion,
3. Best practices for industry to address these red flags, and
4. Screening tools and resources to assist with due diligence.
Key points include the implementation of advanced technologies to track and trace goods, continuous monitoring and reporting of suspicious activities to relevant authorities.
‘This guidance is a vital tool for industries to ensure they are not inadvertently contributing to the evasion of export controls and sanctions,’ BIS said in its press release.
‘Preventing Russia from obtaining the components it needs to power its deadly missiles and UAVs is a top priority for G7 members,’ said the Commerce Department’s Assistant Secretary for Export Enforcement Matthew Axelrod. ‘But the G7’s anti-diversion efforts cannot succeed without the partnership of industry, which is why we today issued our first-ever guidance document designed to provide industry across the G7 the information necessary to identify and respond to Russia’s changing evasion tactics,’ he said.
