UK issues guidance to counter Russian sanctions evasion through third countries

The UK government has published detailed guidance for businesses to combat Russian efforts to circumvent sanctions through third-country procurement networks, warning that Moscow continues to acquire Western military and dual-use goods despite trade restrictions.

‘Russia is going to great lengths to circumvent sanctions, and continues to procure Western military, dual-use, and other critical goods through third countries, including beyond battlefield technologies,’ the Department for Business and Trade said in guidance published 7 January.

The document identifies 14 countries requiring ‘enhanced due diligence’ for certain exports, including China, India, Turkey and several Central Asian nations, while noting these jurisdictions are ‘taking steps to reduce the flow’ of sensitive goods to Russia.

Key high-risk items include integrated circuits, electronics components, manufacturing equipment, industrial machinery, aeronautical instruments, and vehicle parts.

The guidance warns that Russian procurement networks often use ‘deceptive tactics’ such as front companies, indirect shipping routes and falsified end-use documentation to get around sanctions.

The government also released template language for a ‘no re-export to Russia’ clause in contracts, though this remains optional for UK exporters unlike in the EU where such provisions are mandatory for certain goods.

‘Reducing Russia’s capacity to prolong the war in Ukraine remains in the interests of the security and economic prosperity of all UK businesses and persons,’ the guidance states, urging companies to report suspected violations to authorities.

https://content.govdelivery.com/accounts/UKFCDO/bulletins/3cb1bb4