Sanctions Circumvention Guidance for European Operators
On 7 September 2023, the European Commission released a guidance note to assist European operators in recognising and avoiding sanctions circumvention risks. This guidance is crucial to ensure compliance with EU law and address the challenges posed by sanctions, especially in response to Russia's aggression against Ukraine.
Due diligence obligation
EU operators are required to conduct due diligence when trading with third countries to prevent sanctions circumvention. The guidance serves as a practical guide for EU operators to conduct strategic risk assessments and reduce exposure to circumvention schemes.
Enhanced due diligence
For operators at higher risk, the guidance outlines guidelines for enhanced due diligence. It offers best practices for assessing business partners, transactions, and goods.
The guidance provides a list of circumvention red flags specifically concerning business partners and customers. These indicators help EU operators identify possible risks when entering into commercial relationships with new trading partners. The guidance also offers practical examples to help companies put the recommended practices into action.
The practical guidance aims to strengthen EU operators' ability to identify warning signs and reduce the risk of sanctions evasion.
