On 22 May 2023, the UK’s Export Control Joint Unit published a Notice to Exporters on trade sanctions circumvention (the Notice). The trade sanctions aim to restrict Russia’s access to goods, technologies, and revenue that could be used to support its illegal war.

The purpose of the Notice is to prohibit the undermining of trade sanctions, export controls, and other restrictive measures that were put in place in response to Russia's invasion of Ukraine. At the same time, it raises awareness of the risks and obligations associated with dealing in sanctioned goods.

The Notice highlights several key risk indicators relating to customer, product, and location, which can indicate an attempt to bypass existing trade controls. Robust due diligence and internal governance are key to managing sanctions-related risks. Even when dealing with established counterparties, continued vigilance and periodic due diligence is essential to ensure that the risk exposure remains the same.

Traders are advised to incorporate an assessment of these risk factors as part of their due diligence.

The Notice can be found here.