This summary AML Alert Russia Sanctions – Trade Sanctions Circumvention has been produced by the Accountancy AML Supervisors’ Group (AASG) from an extract from the Department of Business and Trade Notice NTE 2023/08: Russian sanctions – Trade sanctions circumvention.
The Department of Business and Trade issued notice NTE 2023/08 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 those working in the accountancy profession so that they don’t become party to the trade sanctions circumvention.
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. Businesses, and their accountants, should ensure that they consider these risks as part of their due diligence. This summary AML Alert highlights the key risk indicators.
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