The European Commission published, on Thursday 7 September, guidance for economic operators to help them identify those in their sector involved in transactions that circumvent the sanctions imposed by the European Union in response to Russia’s military invasion of Ukraine.
In particular, the EU institution is recommending the introduction of internal risk assessments for European exporters. These assessments should include the identification of concrete threats related to the activities undertaken, the development and implementation of measures to limit exposure to the risks identified and the regular updating of internal due diligence procedures.
The guidance also suggests including specific clauses in export contracts prohibiting products sold and services provided from being re-exported to Russia or Belarus. In the banking and finance sectors, European economic operators are invited to use various criteria to identify risky counterparties, including geographical location, recent creation or recent changes in shareholding.
The guidance also includes lists of critical components used on the battlefield and a list of goods considered critical.
To see the Commission’s guidance: https://aeur.eu/f/8h2 (Original version in French by Mathieu Bion)