TRADE WITH RUSSIA & THE UKRAINE – SANCTIONS & EMBARGOES

The UK government has imposed a range of sanctions measures, including trade and financial sanctions, under The Russia (Sanctions) (EU Exit) Regulations 2019 (“the Russia Sanctions Regulations”).

In addition further information can be found at https://www.gov.uk/guidance/trading-under-sanctions-with-russia?utm_medium=email&utm_campaign=govuk-notifications-topic&utm_source=2bf2bdb6-39f1-48d0-9928-11d599136dee&utm_content=daily

The purposes of the Russia Sanctions Regulations are to encourage Russia to cease actions:

  • destabilising Ukraine, or
  • undermining or threatening the territorial integrity, sovereignty or independence of Ukraine

Find detailed guidance on all sanctions at https://www.gov.uk/government/collections/uk-sanctions-on-russia

UK businesses are responsible for the decision on whether to trade with Russia.

Business should expect a high unpredictable trading environment as a result of:

  • designations of individuals and entities under the Russia Sanctions Regulations by the UK
  • retaliatory measures by Russia

The Russia Sanctions Regulations affects several aspects of trade with Russia, including:

  • the movement of goods to and from Russia
  • the settling of financial transactions with suppliers and customers
  • trading with certain businesses and individuals

BIFA has noted a significant increase in enquiries regarding sanctions and embargoes, particularly for shipments transiting within the EU, where carriers are seeking clarification as to what checks are being carried out by shippers and freight forwarders to ensure that goods are not being delivered to a sanctioned individual.

One such incident highlighted the issue, a shipment destined to a Russian national based in the Democratic Republic of the Congo transhipped via Brussels where it was stopped.  Investigation established that the Russian individual was actually subject to sanctions and the consignment was seized by Belgium Customs.

Dealing with sanctions and embargoes is complex; particularly where individuals adopt aliases and information provided by government can be highly detailed.

Commercially available software can be used to check for sanctions and embargoes. In addition, we suggest that Members should consider seeking legal advice if they plan to continue trading with Russia.