The European Commission has published guidance for exporting companies providing a comprehensive overview of due diligence requirements to prevent circumvention of sanctions against Russia.
“This practical guidance will help EU exporters spot red flags and reduce the risk of sanctions evasion,” Commissioner for Financial Services, Financial Stability and Capital Markets Union Mairead McGuinness said.
Under EU law, European operators are obliged to perform due diligence when trading with third countries to ensure that their business partners do not circumvent EU sanctions.
The guidance outlines the steps that European exporters should take during their due diligence process for trade operations to prevent violations of EU sanctions.
The guideline includes a list of indicators that may suggest that new trading partners are inclined to circumvent EU sanctions.
Exporters are advised to pay attention to such indicators as a complicated route of transportation of goods, atypical documentation, complex payment schemes, etc.
“EU support for Ukraine is steadfast. EU sanctions are having a real impact on Russia’s ability to wage war, and therefore Russia is desperately searching for ways to circumvent them. The lengths that Russia will go to get around our restrictions are increasingly complex and opaque,” McGuinness emphasized.
The guidance was likely published in response to the discovery of numerous spare parts, manufactured outside Russia, found in Russian military equipment, including missiles and drones.
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- Some 450 foreign-made microelectronic components identified in Russian weapons recovered in Ukraine – RUSI
- Millions of Dutch chips end up in Russia despite EU sanctions – NOS/Nieuwsuur investigation
- Ukraine intel names companies whose guidance microchips found in Russian weapons