天美影院

This guide is produced by the Foreign, Commonwealth and Development Office (FCDO) to help businesses in Armenia that are seeking to comply with UK sanctions.听听

This guide is general, so you should also refer to the relevant up-to-date legislation, including Governmental Decrees.听

While every effort has been made to ensure the accuracy of the information in this guide, it does not constitute legal advice and cannot be relied upon as such.鈥疘f you are unsure about your obligations in any given case, you should take independent legal advice.听

This guide is specific to sanctions targeting Russia, but the UK has other sanctions regimes in place. View a full list of UK sanctions regimes.听

1. Aim of this guide听

This guide is published by the UK government to help businesses in Armenia to be aware of:听

• restrictions in Armenia鈥檚 national laws relevant to doing business with persons sanctioned by the UK and with Russia听听
• the risks of losing access to services and goods provided by UK and other international banks and suppliers if they are concerned that you may be dealing with sanctioned persons or exporting sanctioned goods to Russia听
• practical steps you can take to manage the risks of potentially severe disruption to your business听听

2. Context听

The UK and its international partners have implemented sanctions on an unprecedented scale in response to Russia鈥檚 invasion of Ukraine. The UK has designated over 2,000 individuals and entities and has imposed wide-ranging restrictions on trade and other forms of economic activity involving Russia.听

UK sanctions aim to:听

• encourage Russia to cease activity which destabilises Ukraine or undermines its territorial integrity, sovereignty and independence听
• promote the payment of compensation by Russia for damage, loss or injury suffered by Ukraine since February 2022 as a result of Russia鈥檚 invasion

The UK government will keep these sanctions in place until these objectives have been achieved.听

3. Why this matters to businesses in Armenia听

3.1. Circumvention of UK sanctions听

Russia is going to great lengths to circumvent sanctions, and continues to procure Western military, dual-use, and other critical goods through third countries, including beyond battlefield technologies. Russia relies on deceptive tactics, such as the use of indirect shipping routes, deliberate falsification of the end-uses of traded goods, and professional evasion networks.听

For example, in the context of Armenia, this might include:听

1. A firm in Armenia may receive an order from a Russian importer for goods that are subject to UK sanctions and so cannot be obtained directly from the UK.听听

2. The Armenian firm orders the goods from a UK supplier without informing them or others involved (such as banks, insurers, shippers) that the end-user of the goods is in Russia.听听

3. The UK supplier exports the goods to the Armenian firm, which then re-exports them to Russia.听听听

This type of practice and others like it constitute the circumvention of sanctions. These risks may affect all parties in a supply chain, irrespective of the form of their involvement or their size. The .听

3.2. Who must comply with UK sanctions听

UK sanctions are instruments of UK law. The UK does not take civil or criminal enforcement action in relation to breaches of UK sanctions against persons outside the UK unless they are:听

• UK nationals, for example among the staff or directors of a non-UK business听

• UK-incorporated companies, including their unincorporated overseas branches. Subsidiaries incorporated outside the UK are generally outside UK jurisdiction except if either of the following points is applicable to their activities:

  • conducting any part of their business in the UK, for example travelling to the UK to negotiate or sign a contract with a supplier听
  • buying services such as insurance, banking, clearing or legal services on UK markets but using them overseas听

If any of these criteria are applicable, those involved may become liable to penalties or prosecution in the UK, potentially including severe fines, if they breach UK sanctions. They are expected to have in place strong and effective measures to ensure that no goods or services that they supply to a third country, such as Armenia, are diverted to Russia or to sanctioned persons. All those subject to UK jurisdiction are referred to in this guidance as 鈥楿K Persons鈥�.听

3.3. Risks for Armenian businesses听

However, while only UK Persons are legally obliged to comply with UK sanctions, non-UK persons based overseas who facilitate the circumvention of are not subject to UK sanctions face certain risks, as follows.听听

3.3.1. You may be sanctioned听听

The UK may impose sanctions directly on you as an individual or on entities that you own or control if you are involved in activities could contribute to Russia鈥檚 invasion of Ukraine, or which assist in the contravention or circumvention of certain UK sanctions. The UK has already imposed sanctions on this basis on businesses in a range of third countries.听

Even if you are not a UK Person, becoming subject to UK sanctions can have serious consequences for your business and other financial dealings. UK sanctions bind UK nationals and entities everywhere. Therefore, if you are designated by the UK, it will prevent UK nationals, businesses, and any other persons in the UK from providing you with access to the UK economy. In addition, many international businesses may voluntarily choose not to do business with you 鈥� behaviour often described as de-risking.听听

In practice, this may mean:听

• all UK businesses must, and many international businesses may, refuse to conduct any business with you as well as with any entities that you own or control. This could mean that UK businesses refuse to supply goods to you, purchase goods from you, repair or service your equipment, or provide most professional and business services to you听听
• all UK and many international banks would freeze any of your assets that they hold and would refuse to provide you with any services听
• if insurance or shipping/freight services are to be provided by UK firms, they will also refuse to take on your business if you or any of other the parties or goods concerned are sanctioned听

3.3.2. You may be considered a high risk by UK suppliers听

UK sanctions may impact your business if you do not take the requirements of UK sanctions into consideration within your own business operations.听听

This is particularly the case where UK persons are involved since they are required to ensure that their activities do not circumvent UK sanctions. If a UK company (including a UK bank) supplies you with goods or services, they will want to be assured that these will not be passed on to, or be for the benefit of, a UK-sanctioned person, or to Russia or to a 鈥榩erson connected with Russia鈥� if that would be in breach of UK sanctions. (A 鈥榩erson connected with Russia鈥� means an individual or a combination of individuals who are located or ordinarily resident in Russia, or an entity that is incorporated or constituted under the law of Russia, or domiciled in Russia.)听

Accordingly, some UK companies may take a cautious approach (sometimes termed 鈥榙e-risking鈥�) and refuse to do business with you on the grounds that, for example:听

• a sanctioned person holds a minority interest in your company听
• you have links with sanctioned persons听
• they have any other concerns that they are unable to resolve to their satisfaction听
• they prefer to adopt a cautious approach on the basis of their internal policies听

As a result, many UK Persons will decline to do business with you if you are unable to demonstrate that you have implemented effective measures to prevent any goods or services that you receive from them being sent to Russia or to a person connected with Russia. This may apply whether they are sent directly by you or indirectly by others in your supply chain. This could make it difficult for you to access, for example:听听

• components used in your manufacturing processes听
• goods that you trade听
• 颈苍惫别蝉迟尘别苍迟听
• 颈苍蝉耻谤补苍肠别听
• 产补苍办颈苍驳听
• 蹿颈苍补苍肠颈苍驳听
• debt servicing听
• payments services听
• foreign exchange services听
• letters of credit听
• servicing and spare parts for machinery听

If UK persons are unable to resolve concerns to their satisfaction, they may also choose to halt trading with your business altogether, including the importation of goods to the UK.听听听

In addition, it is possible that some non-UK businesses will refuse to do business with you if you are unable to demonstrate that you have taken UK sanctions into account. This is particularly the case with financial institutions, such as banks, which may refuse to process transactions which are at risk of breaching or undermining UK sanctions.听

It is also important to note that the national laws of Armenia may regulate some of the same activities that are prohibited by UK sanctions. They may restrict what can be exported or re-exported to Russia. Details on such laws in Armenia are set out in section 5.听

4. Overview of UK sanctions on Russia听

Given the risks for Armenian businesses identified in the preceding section, this section explains the main features of UK sanctions. While only UK persons are legally obliged to comply with these regulations, understanding how UK sanctions operate is important for informing the steps you should undertake if you are seeking to manage the risks identified above. Practical guidance on such steps is set out in section 6.听

The UK government publishes statutory guidance on its Russia sanctions. This guidance is not exhaustive.听More detailed guidance is also published on certain issues, listed in section 7. You should also seek legal advice where you are uncertain of your obligations, or of the sanctions risks involved.听听听听

4.1. Legal basis听

UK sanctions on Russia are set out in:鈥�鈥�(the 鈥楻egulations鈥�), as amended from time to time. The link takes you to the full text of the Regulations. If you want to investigate a specific issue in the Regulations, for example to check whether goods you are dealing with are sanctioned, we have set out some tips to help navigate this legal text in section 7.1.听

Two aspects of UK sanctions measures are relevant to businesses in Armenia:听

• asset freeze designations听
• trade in high priority goods听听

Details on each of these types of sanctions are set out below, followed by a summary of the other main types of UK sanctions.听听

4.2. Financial sanctions

4.2.1. Asset freeze designations听

Asset freeze sanctions play a critical role in targeting individuals and entities that support Russia鈥檚 military in its invasion of Ukraine, cutting them off from access to funds and business.听Individuals and entities subject to an asset freeze are known as 鈥榙esignated鈥� or 鈥榮anctioned鈥� persons.听

As set out in section 3, if goods or services are to be supplied to Armenian persons by a UK company, the UK supplier will want to be assured that these will not be passed on to, or be for the benefit of, a UK-designated person. Without adequate assurances, the UK supplier 鈥� including any UK banks involved 鈥� is likely to decline the business.听听

This section explains where you can find out whether a person with whom you propose to do business is a designated person. This includes an explanation of the concept of 鈥榦wnership and control鈥� since UK designations apply not only to persons that are designated in their own names but also to entities that they own or control, which requires additional due diligence.听听

4.2.2. How to check who is designated听

All individuals and entities designated by the UK are included in the 鈥楥onsolidated list鈥�. This is updated immediately whenever changes are made, which occurs frequently. Guidance on how to check whether an existing or prospective partner or customer of yours is designated can be found in section 6.3. The UK Government also issues e-alerts to businesses to inform of changes to the Consolidated List. Details can be found in Section 7.4.听

4.2.3. Ownership and control听

This section provides an explanation of the concept of 鈥榦wnership and control鈥� since UK designations apply not only to persons that are designated in their own names but also to entities that they own or control. Ensuring compliance therefore requires additional due diligence than simply checking the Consolidated List. More detailed guidance can be found in section 6.3.听

An asset freeze applies not only to those who are listed in the Consolidated List, but also to entities if:听

• a designated person holds, directly or indirectly, more than 50% of the shares or voting rights in the entity听听
• a designated the person has the right, directly or indirectly, to appoint or remove a majority of the board of directors of the entity, or听听
• it is reasonable to expect that a designated person would be able to ensure that the affairs of the entity are conducted in accordance with their wishes. Details of how this may be interpreted are set out in the UK financial sanctions general guidance

Such entities may not be designated in their own right, so their names may not appear on the Consolidated List. But they must nonetheless be treated as subject to an asset freeze.听

If 2 or more designated persons together hold more than 50% of the shares in an entity, but each one holds less than 50% and if there is no evidence of a joint arrangement between them or that the shares are held jointly, the entity is not considered to be owned by a designated person.鈥�.听

Before conducting a transaction, the FCDO strongly recommends you check:听

• whether any of the parties to the transaction are listed in the Consolidated List
• whether they are owned or controlled by any person in the Consolidated List听

This is particularly important for any transactions by Armenian businesses that involve UK parties, given that it is prohibited for a UK Person to:鈥�听

• deal with the funds or economic resources belonging to or owned, held or controlled by a designated person鈥�听
• make funds or economic resources available, directly or indirectly, to, or for the benefit of, a designated person听
• engage in actions that, directly or indirectly, circumvent the financial sanctions prohibitions鈥�听

The funds and economic resources must be 鈥榝rozen鈥� immediately by the UK Person in possession or control of them.听听

Funds or economic resources are considered to be owned by a designated person, and must therefore be treated as 鈥榝rozen鈥�, if:听

• a designated person owns any legal or equitable interest in them听
• they are owned jointly with a non-designated person听

4.2.4. Exceptions and licences听

The UK government issues a number of licences that permit certain activities that would otherwise be prohibited. There are 2 types of licence:听听

1. General licences: these authorise specified activities that would otherwise be prohibited, without the need to obtain a specific licence. The UK government publishes a list of the General Licences which is frequently updated as new licences are issued and existing licences expire. General licences include requirements for prior notification of use, record-keeping and reporting.听

2. Specific licences: these may be issued in response to an application 鈥� which may be submitted by UK persons, or a company that employs UK persons, or by designated persons, or by their representative (for example, a law firm acting on their behalf) 鈥� if the circumstances meet one of the licensing grounds listed in . These are limited and include, for example:听

• to meet the basic needs of a designated person听
• to settle a pre-existing judicial decision听
• to satisfy an obligation that arose before the person was designated听
• for humanitarian, medical or food-related activities听

The Regulations provide for certain exceptions to asset freeze sanctions. These apply automatically in certain defined circumstances and do not require a UK Person to obtain a licence. Read more information about exceptions. The circumstances in which these exceptions apply are very limited and you should seek legal advice before assuming they apply to you.听

4.3. Trade sanctions

The UK has imposed extensive trade sanctions against Russia, covering the majority of goods and services. A key priority of UK trade sanctions is to prevent Russia from acquiring goods which contribute directly to its military. Goods which are of particular concern in this respect are published in the Common High Priority List, which has been jointly compiled by the US, EU, and Japan. While the CHPL is not an exhaustive list of sanctioned goods (see section 4.3.2), and all circumvention of UK sanctions is treated seriously, businesses based in Armenia should exercise caution when trading these CHPL goods if there is risk that Russia may be their ultimate destination.听

As set out in section 3, if goods or services are to be supplied by a UK company, it will want to be assured that these will not be passed on to Russia or to a person connected with Russia if that would be in breach of UK sanctions. Without adequate assurances, a UK supplier 鈥� including any UK banks involved 鈥� is likely to decline the business.听

4.3.1. Activities subject to UK sanctions听

UK sanctions on certain goods and technology include prohibitions on the following range of transactions. These sanctions apply to goods and technology that are specifically listed in the Regulations. A practical guide to how to check whether a specific item is subject to UK sanctions is in section 7.1. While only UK Persons and persons located in the UK are obliged by law to comply with these restrictions, Armenian businesses that participate in these transactions may expose themselves to the risks outlined in section 3.3.听

The below sets out, in high level summary, the activities that are restricted by UK trade sanctions.听The precise terms of the restrictions will vary depending upon the specific goods or services you are dealing with. More information is in Russia sanctions guidance.听听听

• exporting sanctioned goods directly from the UK to Russia
• exporting sanctioned goods from the UK 鈥榝or use in鈥� Russia; this includes, for example, if the goods are sent to a third country but are then sent on to Russia

• Importing sanctioned goods into the UK if they are consigned from Russia or they originated in Russia; this includes, for example, sanctioned goods that are not shipped directly from Russia to the UK but are sent via a third country
• directly or indirectly acquiring sanctioned goods with the intention of the goods entering the UK, if they originate in Russia, or are located in Russia, or they are from a person connected with Russia

• supplying and delivering sanctioned goods, directly or indirectly:
  • from a third country to Russia
  • from Russia to a third country or
  • between third countries

• for use in Russia
• to a person connected with Russia

• to a place in Russia
• to a person connected with Russia
• from Russia to persons or places outside the UK

• directly or indirectly providing technical assistance in relation to sanctioned goods:
  • to a person connected with Russia
  • for use in Russia
  • to designated persons (in relation to aircraft and ships)

• directly or indirectly providing financial services or funds to a person connected with Russian in connection听with sanctioned trading activities.

• directly or indirectly providing brokering services related to the supply or delivery of sanctioned goods:
  • from a third country to a place in Russia or
  • to a person connected with Russia

Similar restrictions apply to the regions of Ukraine that are not controlled by the Ukrainian government (Crimea, Donetsk, Luhansk, Kherson and Zaporizhzhia).听

4.3.2. Goods subject to UK sanctions听

The sanctions on exports (and related activities, as listed above) to Russia apply to a wide range of goods and, in some cases, technology including (with links to the relevant Regulations):

• military, dual-use and internal repression items ()听

• advanced technology, aviation, maritime and space items ()听

• energy-related items (听

• luxury items (the sanctions apply to listed goods above certain values, including cars valued at over 拢42,000) (听

• a wide range of goods for which Russia is particularly reliant on supplies from the UK and its G7 partners, or which are of significant importance for the Russian economy ( and )听

The sanctions on imports from Russia (and related activities, as listed above) similarly apply to a wide range of goods and technology including:听听

• oil and oil products, liquefied natural gas, and coal and coal products (, and )听听

• certain iron and steel items, including Russian iron and steel that has been processed in third countries ( and )听

• certain materials and manufactured items generating revenue for Russia ( and )听

• gold and diamonds, including items processed in third countries (, , and )听听

4.4.1. 天美影院听

UK sanctions on services include bans on the provision of the following:听

• professional and business services including: accounting, business and management consulting, public relations, advertising, architectural, auditing, engineering and IT consultancy and design services to persons connected with Russia, and legal advisory services to any person who is not a UK person in relation to any activity which would, if carried out by a UK person or in the UK, contravene UK sanctions on Russia听

• maritime transport, insurance and other financial services for ships carrying Russian crude oil/refined oil products to or between third countries, unless the crude oil/refined oil products has been sold below a specific price cap听

• a ban on all Russia-owned or operated aircraft and ships from UK airspace, landings, and ports, and on aviation and shipping technical assistance to, or for the benefit of, designated persons

4.4.2. Exceptions and licences听

As is the case for financial sanctions, the UK government issues a number of licences that permit certain trade activities that would otherwise be prohibited. There are 2 types of licence: general and specific licences.听

1. General trade licences: these authorise specified activities that would otherwise be prohibited, without the need to obtain a specific licence. These include a that are below a 鈥榩rice cap鈥�. General trade licences include requirements for prior notification of use, record-keeping and reporting.听

2. Specific licences: these may be issued in response to an application听鈥� which may be submitted by UK persons, or a company that employs UK persons, or by their representative (for example, a law firm acting on their behalf) 鈥� but only if the circumstances meet one of the licensing grounds set out in the statutory guidance. These include:听

• humanitarian assistance, or to protect health, safety or the environment听
• medical and pharmaceutical purposes for the benefit of the civilian population听
• divestment under certain conditions听
• ensuring critical energy supply to any country听

The Regulations also provide for limited exceptions to trade sanctions, which apply automatically in certain defined circumstances as set out in the Regulations and do not require UK Persons to obtain a licence. The exceptions include, in summary:听

• personal effects听
• consumer communication devices and software updates听
• certain exceptions for aircraft and ships, and maritime goods听
• certain exceptions relating to professional, business and legal advisory services听
• certain iron and steel imports听
• oil and oil products that transit through Russia听

The circumstances in which these exceptions apply are very limited, and you should seek legal advice before assuming they apply to you.听

4.5. Other types of sanctions听

In addition to the measures described above, the UK sanctions cover a range of other activities. These are not addressed here since they are less likely to be relevant to businesses operating in Armenia. Further information is in UK statutory guidance.听听

5. Relevant national Armenian laws and policy

Armenia does not implement UK sanctions or its own national sanctions. However, certain Armenian laws and measures regulate some of the same activities that are prohibited by UK sanctions. This section sets out a summary of such laws.听听

The UK government does not take responsibility for the accuracy of the content of this section. When operating under Armenian jurisdiction you should consult relevant official sources of information and should seek appropriate qualified legal advice.听听听

The purpose of this section is to highlight additional barriers and risks that individuals and entities operating in Armenian may face if they participate in activity that may circumvent UK sanctions.听

5.1. Measures applicable to the Armenian financial sector听

Banks and other financial services firms in Armenia are required to comply with measures issued by the (Central Bank) and the (Central Depository). They have adopted a number of measures that may in practice restrict business related to Russia or persons connected with Russia. Such measures may also mean that Armenian banks and financial services firms refuse to handle certain transactions if they have concerns that they are not compliant with UK (or other) sanctions:听

Central Bank measures:听

• the requires reporting entities to identify, prevent, and report suspicious transactions and business relationships to the Central Bank. Reportable transactions include money laundering, terrorism financing, or other illicit activities which may include potential sanctions violations

• under the , any 鈥渟ignificant transactions鈥� (exceeding AMD 20 million) must be reported with details including information about ultimate beneficial owners

Central Depository measures:听听

• the Central Depository has issued with updated operational policies for the securities market. This includes a 鈥淧olicy on Compliance with International Sanctions鈥� which establishes a framework for the Central Depository to comply with UK and other international sanctions听听听

• the Central Depository has recently required Central Depository operators to confirm the extent of adherence to international sanctions, including UK sanctions

5.2. Measures by Armenian banks听听

In addition to the measures mandated by the Central Bank and Central Depository listed above, Armenian banks may restrict or refuse services to clients that are subject to UK or other foreign sanctions.听

• under the ,听banks have the right to choose their clients and may refuse services based on their internal risk assessments, which might include considerations of reputational risk and potential legal liabilities associated with dealing with sanctioned entities

• under the ,听depending on the risk factors, financial institutions can decide or might be obliged to refuse opening an account, suspend a transaction and in case of suspicion of terrorism, freeze assets

5.3. Trade measures听

controls the export of certain sensitive goods.听This list of goods is continually reviewed (last updated in March 2024) and includes goods that the UK and its allies consider as Common High Priority Items (CHPIs).听听听

A licence from the State Revenue Committee is generally needed for the export of such goods to Russia.听听

There are limited exemptions which permit exports for:听听

• personal use (quantities not to exceed commercial quantities specified under )听

• the organisation of exhibitions, cultural events, sports events, international forums, or state meetings, provided that the goods are exported back to the country from which they were imported听听听

5.4. Penalties and enforcement听

Armenian businesses that fail to observe the requirements set out above may be subject to a range of penalties:听

• the Central Bank may require additional training, subject the financial institution to enhanced scrutiny (audits), enhancement of compliance personnel, and in appropriate circumstances withdraw the financial institution鈥檚 licence to operate
• the Central Bank has the authority to suspend any transactions, whether monetary or securities-related, if it identifies a reasonable risk of violating anti-money laundering legislation听
• violation of anti-money laundering laws can lead to administrative fines and criminal penalties听听
• the Armenian Customs Code provides for various customs offences (for example, illegal export or import of goods, breach of conditions of customs procedures) which can be subject to penalties such as a warning, fine, confiscation of goods, or imprisonment.听
• goods listed under Decree 808 can be stopped at the border if exported without an appropriate licence听
• the Armenian Criminal Code provides for attribution of criminal liability to legal entities听听

6. Practical steps to manage sanctions risks and promote compliance听

There is no 鈥榦ne-size-fits-all鈥� approach to managing sanctions risks. In general, best practice is to conduct a risk assessment of the specific activities of your business and then to design and implement a company sanctions policy to manage the risks effectively. The following outlines simplified, practical steps to assist in this process.听

6.1. Risk assessment听

Drawing on the information in this guide and other sources of guidance (such as those listed in section 7), identify and assess the risks for your business of:听

• breaching national laws听
• conducting transactions that, while not a breach of national laws, may nonetheless have consequences for your ability to trade in the future听

Risk profiles (also sometimes referred to as 鈥榬ed flags鈥�) may include the following. This is an illustrative list and not intended to be exhaustive. It is drawn from various sources of guidance, including the UK鈥檚 countering Russian sanctions evasion guidance for exporters and G7 updated industry guidance, preventing Russian export control and sanctions evasion.听

• sanctions designations:听听

  • are they designated persons or are they owned or controlled by designated persons, or is this information unavailable (guidance on how to conduct these checks is in section 6.3)听

  • did they have a change of ultimate beneficial ownership shortly before or after sanctions were imposed听

  • do they have links with designated persons, such as joint ventures or cooperation agreements听

  • are their address or contact details similar to those of a designated person听听

• connected with Russia:听

  • are they individuals who are resident or located in Russia听

  • are they companies that are established or domiciled in Russia听

  • are they overseas branches or subsidiaries of Russian companies听听

  • do they do business with Russian companies, particularly those in the Russian defence sector听

• possible front companies:听

  • are they reluctant to provide clear details about themselves. Do they have no website or little information on it听

  • do they use unnecessarily complex trading processes, for example using layered letters of credit, intermediaries, or brokers听

  • does their address not appear consistent with their business or is it a residential address听

  • do they share their premises or registered address with multiple businesses or holding companies dealing in comparable goods 鈥� this may be intended to conceal illicit trade in sanctioned goods听

  • are they recently established, or reactivated or have they had recent changes in their ownership or control听

  • do they have little or no prior history of purchasing the item in question听

  • are communications routed via a representative while senior management staff are not available听听

  • do they decline routine installation, training, or maintenance services associated with the product听

• end-use of the goods听

  • is there any reason to suspect that they are engaged in sanctions evasion听听

  • is the intended end-use of the goods clear and rational, or are they reluctant to provide details about this听

  • do their supporting documents, such as the invoice, contain inconsistent information or not list the actual end-user but instead name only an intermediary such as a mail centre, trading company or logistics company听

• are they imported, directly or indirectly, from the UK (or other countries that have imposed sanctions on Russia)听

• are they subject to any sanctions or export or import controls 鈥� check their commodity codes. In particular, are they on the list of CHPLs; does your UK supplier inform you if any items are sanctioned or CHPLs听听

• do they contain components that are on the list of CHPLs and are liable to be extracted and diverted听

• is your proposed trade inconsistent with normal trade patterns, for example have the volumes or prices of the goods increased significantly since the imposition of sanctions听听

• do the goods not fit the nature of the customer鈥檚 business, for example, an order of sophisticated computers for a small bakery听

• is there any reason to suspect that the goods鈥� country of origin or commodity code has been falsely declared听

• do they use an abnormal or circuitous routing of the goods听

• are invoice values divided into smaller amounts to remain under the value limits of sanctioned goods or export controls听

• do your customers use shell companies to conduct international wire transfers听

• do they use crypto currency for payment听

• do they use circuitous routing of financial flows, for example outside of SWIFT, via small overseas banks听

• are purchases made under a letter of credit that is consigned to the issuing bank, not to the actual end-user听

• are they not interested in guarantees, maintenance, service, spare parts听听

• do transactions involve a last-minute change in payment routing through a different country or company听

• is the customer willing to pay significantly above the market rate for the goods听

6.2. Establish a company policy听

On the basis of the risk analysis of your business, establish a company policy on sanctions compliance. This does not need to be long or complex but should be proportionate to the risks and be effective in managing them. An illustrative example of 3 main components of a policy:听

1. Signal senior commitment to compliance by the Chief Executive Officer (CEO), assign responsibilities for tasks, and provide training and raise awareness of staff.听

2. Conduct due diligence on your current and prospective partners and customers, considering the questions listed in the risk assessment. Require them to clarify any issues that are not clear and, if the goods are subject to sanctions, to sign an end user certification, certifying that the goods will not be supplied to Russia and include provisions in your contract requiring their compliance. Further detail on these points is set out below.听

3. Keep your policy updated. Be alert to changes in the national laws and sanctions, and adapt your procedures as necessary. Conduct checks and audits to ensure the procedures are effective. Update your staff training regularly.听

6.3. Check whether your partners/customers are subject to an asset freeze听

For existing partners and customers: these should have been checked as part of the risk assessment process in section 6.1. The same checks should be repeated regularly, in case they are added to the sanctions list in the future.

For prospective new partners and customers, the same checks should be conducted. Screening of the names and details of existing and prospective partners and customers may be conducted manually or by using commercial software tools. A screening check involves:听

1. Check the name: search for the name and, separately, the address, in鈥�OFSI鈥檚 Consolidated list using 鈥楥ontrol F鈥� or using . If you find a match for the name, check the other details provided in the lists (such as aliases, dates of birth and addresses) to confirm whether the match is accurate. An address which matches one in the sanctions lists may indicate the use of shell companies or trust and company service providers. You should investigate this further.听

2. Check ownership: if a partner or customer is not named in any of the sanctions lists, you should also investigate whether they are owned more than 50% by a designated person, as described in section 4.3.2. These details may be provided by the partners or customers themselves but you should check these against public sources.听You should proceed with caution if reliable information on the identities of the owners and ultimate beneficial owners cannot be found or if there is any reason to suspect that they are owned by a designated person.听

3. Check control: if a partner or customer is not designated in their own names nor owned by a designated person, you should also consider whether they are controlled by a designated person, as described in section 4.3.2. Again, it is advisable to treat partners and customers with caution if there is any reason to suspect that they may be controlled by a designated person.听

If a partner or customer is designated, or they are owned or controlled by a person that is designated, or there are serious grounds to suspect that they may be, it is strongly recommended that you do not conduct any form of business with them. Doing so may:听

• contravene national laws听
• lead your banks, suppliers and other partners to stop doing business with you听
• in serious cases, lead to you being designated yourself听

6.4. Check for connections with Russia听

Unlike a sanctions designation, a connection with Russia does not mean that you should not conduct any form of business with a partner or customer. But when considering doing business with a new partner or customer, you should be clear about their history and business practices, and particularly about the end use, end user and ultimate country of destination of the goods that you supply to them. You should:听

• include clauses in your contracts prohibiting the re-export of the goods to Russia and their resale to any third party that does not make the same commitment听
• conduct open-source research, including looking at public business registries and trade databases听
• consider the questions on end-use listed in the risk assessment in section 6.1, to confirm as far as possible that there is no reason to suspect that your goods will be re-exported to Russia. Check for further documentary evidence that supports the customer鈥檚 statements听

• verify the identity and role of any third parties involved in transactions, including brokers, sub-contractors and freight forwarders听

• include clauses in your contracts permitting you not to fulfil the contract without liability if doing so would be either a breach of your national laws or that would cause you to breach your contracts with your UK and other suppliers听

• require a signed end-user certificate stating a credible, legitimate intended end-use of the goods concerned and certifying that the goods will not be supplied, sold, exported or transferred to Russia or to any person connected with Russia, nor to any other person that does make the same commitment (an example of an end-user certification is provided in section 7.2)听

The FCDO strongly recommends that you do not supply to any partner or customer any sanctioned goods, particularly CHPLs, if there is any reason to suspect that your goods may be sent on to Russia. If you do so, you expose yourself to a number of serious risks:听

• contravening national laws听
• leading your banks, suppliers and other partners to stop doing business with you听
• in serious cases, leading to you being designated yourself听

6.5. Regular checks and updates听

Sanctions and the national laws that implement them can change rapidly. Be alert to any changes and update your procedures as necessary. You can sign up for email alerts from the UK government (see section 7).听

Those seeking to evade sanctions are highly resourceful. Circumvention routes and techniques are frequently adapted in an effort to evade detection. It is important to remain vigilant to any emerging signs that your business has been targeted for the purpose of circumvention.听听

Tracking your business鈥檚 trade flows and buyer patterns over a period of time may reveal significant shifts in exports of higher-risk products, indicating the possibility that these products are being procured for diversion to Russia.听

Businesses should continuously evaluate their sanctions risk exposure as the circumvention landscape evolves, to ensure that compliance procedures and due diligence frameworks remain effective.听

You should repeat the process of mapping business-specific vulnerabilities regularly, as business customers and trade flows change, new sanctions are adopted, and circumvention techniques adapt.听听

Even with established trading partners, due diligence should be repeated at intervals to ensure that the risk has not changed. For example, a change of directors, organisational status, or transactional patterns may indicate a more significant shift in a customer鈥檚 business operations.听

Conduct spot checks and audits to ensure the procedures are effective. You should conduct post-transaction reviews to check whether any payments made had any Russian nexus or there is any other reason to be suspicious activities.听

7. More information听

7.1. Checking whether goods are sanctioned听听

1. First, you need the commodity code of the item concerned. (The first 6 digits are the same worldwide under the 鈥楬armonised System鈥�, which is why in some cases these are referred to as 鈥楬S codes鈥�. Individual countries can then add up to another 4 digits for their own classification purposes. Countries may apply slightly different codes to the same product). If you import items from the UK, the UK commodity code will be stated in the commercial invoice. If you do not know the code, you can look it up using the UK鈥檚 Trade Tariff tool.听

2. Check whether such items are included in the Schedules (annexes) of the . There is not currently a search tool available for doing this so the check needs to be conducted manually by searching the Regulations. The following explains how to do this:听

3. Check that you are looking at the latest available version of the Regulations (in the left-hand menu) in the Table of contents page.听

4. Open 鈥楶rint options鈥� in the menu at the top of the page and select 鈥楾he whole instrument鈥� (either PDF or web page).听

5. Use 鈥楥ontrol F鈥� to search for the commodity code of your item, starting with the 4-digit code before progressing to the 6- and 8-digit codes. If the 4-digit code is listed, all goods under that heading are caught by the sanctions, and so on for 6- and 8-digit codes.听

6. The commodity code may be listed in more than one place. Check the number of the Schedule in which it appears and then the Regulations that apply to that Schedule. Some prohibit exports (and related actions) to Russia while others prohibit imports (and related actions) from Russia.听

7. Finally, if your item is not listed, look through . This lists 鈥楥ritical-industry goods and technology鈥� by their description rather than commodity code. Look through the headings and, where relevant, the detailed listings, to check if your item falls within any of the categories. These items are all prohibited for export (and related actions) to Russia.听

7.2. End user certification and contractual clauses听

The following provides an illustrative example of the undertakings that you could ask your customer to sign or to incorporate in your contract, to provide you with assurances that your transaction with them will not result in the circumvention of sanctions. You may find that your suppliers in the UK, the EU, US and elsewhere require you to provide similar certifications or clauses in your contracts.听听

Your customer could be asked to confirm:听

1. They are not designated as subject to an asset freeze under the sanctions laws of the United Kingdom, the United States, the European Union or other applicable national sanctions laws nor are they owned 50% or more or controlled by any person or entity designated under such laws.

2. The Goods will not be sold, supplied or otherwise provided, directly or indirectly, to any person or entity designated as subject to an asset freeze under the sanctions laws of the United Kingdom, the United States, the European Union or other applicable national sanctions laws or any entity owned 50% or more, or controlled by, any person or entity designated under such laws.

3. The Goods will not be sold, supplied or otherwise provided directly or indirectly to, or for use in, Russia or in any other country or region that is subject to sanctions imposed by the United Kingdom, the United States or the European Union where that act would be in breach of the terms of such sanctions if conducted by a national of those countries or of a Member State of the European Union.听

4. The Goods will not be sold, supplied or otherwise provided directly or indirectly to a person that is ordinarily resident or located in, or to an entity that is incorporated or domiciled in, Russia or in any other country or region that is subject to sanctions imposed by the United Kingdom where that act would be in breach of the terms of such sanctions if conducted by a national of the United Kingdom.

5. The Goods will not be exported, sold or otherwise supplied and delivered, directly or indirectly, to a third party unless that third party accepts the commitments listed in this declaration as binding for itself and on condition that the third party is known by us to be trustworthy and reliable in the observance of such commitments.

6. That any violation of a particular undertaking shall constitute a material breach of an essential element of a contractual Agreement, and you shall be entitled to seek appropriate remedies, including, but not limited to: termination of our Agreement; and a penalty.听

7. That they shall immediately inform you of any problems in meeting the commitments listed in this declaration, including any relevant activities by third parties that could frustrate those commitments.听听

7.3. Screening tools听

A range of additional sanctions-oriented screening tools is听available to support businesses in conducting customer due diligence checks.听

Tool	Description
	The Open Sanctions database collates open-source data for business and civil screening purposes
	The War Sanctions portal provides a range of resources to support businesses in conducting due diligence on potential counterparties, investments, and agreements
	TIP is a searchable database listing third-country entities that have shipped CHPL items to Russia since 2023, according to publicly available trade data
碍厂贰鈥�鈥痑苍诲鈥�	The SelfSanctions and LeaveRussia databases, created by the Kyiv School of Economics (KSE), collates data on foreign companies operating in the Russian market supported by鈥�鈥痮n business divestment from Russia

7.4. Useful links听听

• guidance on UK sanctions on Russia
• list of Common High Priority Items (CHPLs)
• Consolidated List of UK financial sanctions targets (designated persons)
• general guidance on UK financial sanctions 听
• guidance on UK financial sanctions on Russia
• FAQs on UK financial sanctions

For further updates and details on designations,鈥�.