Since the commencement of the war between Russia and the Ukraine, BIFA has been warning Members to be extra vigilant when asked to ship goods to Russia.
The Russia sanctions regulations impose financial, trade, aircraft, shipping, and immigration sanctions for the purposes of encouraging Russia to cease actions which destabilise Ukraine, or undermine or threaten the territorial integrity, sovereignty or independence of Ukraine.
Trade sanctions seek to deny Russia access to the goods, technologies, and revenue necessary to pursue its illegal war. The aim of this notice is to prevent the undermining of trade sanctions, export controls, and other restrictive measures designed and implemented in response to Russia’s invasion of Ukraine. Awareness of the risk and obligations in relation to sanctioned goods is an important first step for trade.
Direct trade between the UK to Russia has fallen significantly since sanctions were introduced. However, Russia will seek to procure restricted goods via other routes. As such, there are risks around displacement of trade and diversion of goods to Russia.
One area of particular concern is the circumvention of these regulations, which would undermine these sanctions. Spotting circumvention can be difficult , but the Export Control Joint Unit has provided the following document highlighting area and behaviours to consider.
Members have contacted BIFA with concern at two shipments being tendered to them, and their information is practical and highlights the difficulties of identifying attempts to circumvent sanctions. In both cases there was an unsolicited approach from an overseas entity to shipment goods from the UK. The common points in all cases were :
- That the approach to ship the goods originated outside the UK from traders they could establish very little about
- Direct communication with the perspective overseas client was difficult
- Shipping documents lacked some information, for instance in one case the UK shipper was not mentioned
- Shipments were high end consumer goods or medical goods
- Routings were complex and in one case, there was a request to mark the shipping documents as “being in transit”
In both cases Member’s declined the shipments – their decision was based on no one single fact, rather a cumulation of points and issues.
If Members have concerns about a particular shipment contact should be made with the ECJU by emailing [email protected]
