Countering Russian sanctions evasion - guidance for exporters, 7 January 2025

This guidance is intended to support UK exporters in understanding Russian circumvention practices and in reducing the risk of their business being targeted by those seeking to evade sanctions...

The aim of this document is to support exporters and manufacturers in identifying Russian evasion practices and developing strategies to mitigate the risk of their goods becoming targets of circumvention. It aims to help protect their technology from misappropriation and to prevent the financial loss and reputational harm which could arise as a result of engaging in sanctioned trade.

This guidance document contains:

• information on the range of goods at heightened risk of being diverted to Russia
• red flag indicators of potential sanctions evasion via circumvention
• suggestions for compliance best practice and enhanced due diligence procedures
• additional resources to aid businesses in managing their risk and meeting their compliance obligations...

It is the responsibility of businesses to adopt appropriate measures to mitigate the risk of unwittingly facilitating Russia’s access to sanctioned goods and technologies.

It may be a criminal offence for a UK person or entity to engage in trade that is prohibited under sanctions, or to intentionally participate in activities knowing that the object or effect of them is to circumvent or to enable or facilitate the circumvention of sanctions and export controls...

Alongside our partners in the European Union, Japan, and the United States, the UK government has developed the Common High Priority List (CHPL). This list highlights items that pose a heightened risk of illegal diversion to Russia due to their importance to Russia’s war efforts. It also aids industry in conducting necessary due diligence. As of this document’s publication, the CHPL includes 50 items which Russia seeks to procure for its war effort...

Goods in the following sectors are at generally greater risk of being diverted and re-exported to Russia to circumvent sanctions and export controls. Manufacturers, wholesalers, and exporters in these sectors are advised to implement additional oversight and controls on exported goods:

• military and dual use goods
• aerospace  
• automotive 
• microelectronics  
• heavy machinery...

Companies may wish to conduct enhanced due diligence when exporting at-risk products to certain countries to prevent re-export to Russia, although the risk of each country and individual trade can differ...