Policy & Compliance
Warning on diversion of trade to Russia
S ince 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 fi nancial, trade, aircraft, shipping, and immigration sanctions for the purposes of encouraging Russia to cease actions that 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, and preventing the undermining of trade sanctions, export controls and other restrictive measures designed and implemented in response to Russia’s invasion of Ukraine is paramount. Awareness of the risk and obligations in relation to sanctioned goods is an important first step for trade. Direct trade between the UK and 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 (ECJU) has provided a document ( NTE 2023/08: Russia Sanctions – Trade Sanctions
Circumvention ) highlighting areas and behaviours to consider – scan the QR code below to open the guidance. Members have contacted BIFA with concerns about two shipments being tendered to them. 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 ship goods from the UK. Warning signs The common points in both 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 prospective 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 the BIFA Member declined the shipments – their decision was
Cameron Smith and Jordan Prangnell in a tug during push-back
attendance an experience to remember, including access to the cargo hold, the cabin crew onboard rest area, the cockpit and a ride in a tug as an aircraft was pushed-back ready for departure. Enter the BIFA Young Freight Forwarder of the Year 2023 Award (www.bifa.org/awards) to be in with the chance of attending one of these exclusive tours next year (subject to availability).
based on no one single fact, rather a cumulation of points and issues.
August 2023 | 17
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