Jurisdiction(s):
United Kingdom

UK OTSI Russia sanctions guidance: no-Russia clauses, evasion red flags, high-risk items, due diligence and strict liability enforcement risks

Published on: 17 January 2025

Published by a Law360 reporter

Legal News

Article summary

Background to OTSI guidance

Following Russia’s assault on Ukraine in February 2022, the UK brought in trade sanctions covering a broad spectrum of goods, technology and services. Although direct commerce between the UK and Russia has fallen markedly since these measures were imposed, Russia has continued attempting to source such items indirectly, often via intricate supply chains. This trend has heightened the exposure of UK businesses to sanctions circumvention and the diversion of products to Russia. The methods used to sidestep restrictions are diverse and evolve rapidly, including fabricated end-use details, routed shipments, and the involvement of professional sanctions evasion networks. Participants across supply chains must recognise the diversion threats created by Russia’s procurement activity in this changed environment. Among other provisions, UK trade sanctions bar the export from the UK of sanctioned items to, or for use in, Russia, even where those items are first consigned to another destination. It is therefore vital for UK companies to identify the final destination of their products and to apply rigorous, risk-based due diligence to their counterparties. The new OTSI guidance materials are intended to support exporters in navigating and understanding the altered landscape, diversion risks, and evolving evasion methods outlined above for...

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