The European Commission has published an updated guide to help companies recognise Russian circumvention practices and comply with G7 sanctions. This guide is intended to help industry protect its technology from misuse, avoid reputational damage and minimise liability risks.
The European Commission's guide describes in detail the steps for carrying out risk assessments in order to recognise potential circumvention attempts at an early stage. It also contains specific advice for companies that are exposed to increased risk to ensure that business partners are carefully screened.
The guide also provides a comprehensive list of ‘red flags’ that may indicate possible attempts to circumvent sanctions.
Warnings for sanctions evasion
These "red flags ’ include, for example, unusual payment terms, such as payments from or to countries that are not directly linked to the business partner. Complex or disguised ownership structures are also warning signs. Companies with opaque ownership structures or based in high-risk countries should be viewed with caution.
The same applies to unconventional transport routes where goods are to be transported by unusual or complicated means. Difficulties in identifying the actual end user of the products and orders that are not related to the customer's usual business activities are further warnings mentioned in the guide.
Further contents of the guide
In addition, the updated guide includes a list of goods at increased risk of being diverted to Russia and updated indicators of potential circumvention of export controls and/or sanctions. The guide also provides best practices for industry to deal with these alerts, as well as references to publicly available screening tools and resources to support due diligence.
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