Policy & Compliance
Russian sanctions – a reminder
Dealing with sanctions and embargoes can be complicated, particularly where individuals adopt aliases, while information provided by government is often not in the easiest-to-read formats
M embers are reminded that the UK government has imposed a range of sanctions, including both trade and fi nancial measures, under The Russia (Sanctions) (EU Exit) Regulations 2019 (The Russia Sanctions Regulations). Further information can be found at: https://www.gov.uk/guidance/tra ding-under-sanctions-with- russia?utm_medium=email&utm _campaign=govuk-notifications- topic&utm_source=2bf2bdb6-39f1 -48d0-9928- 11d599136dee&utm_content=daily The purpose of the Russia Sanctions Regulations is 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/co llections/uk-sanctions-on-russia UK businesses are responsible for deciding on whether to trade with Russia. Business should expect a highly unpredictable trading environment as a result of: • Designations by the UK of individuals and entities under the Russia Sanctions Regulations, • Retaliatory measures by Russia. Affected trades The Russia Sanctions Regulations affect 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 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. Sample case 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
“ BIFA has noted a signi fi cant increase in enquiries regarding sanctions and embargoes
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 is often not in the easiest-to-read formats. There is commercially available software that 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.
10 | December 2025
www.bifa.org
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