In September 2023 the EU Commission issued a guidance note for EU operators on implementing enhanced due diligence to shield against Russia sanctions circumvention. It is to help European operators to identify, assess, and understand the possible risks of Russian sanctions circumvention. It includes circumvention red flags related to business partners and customers that EU operators should watch for when they enter into a commercial relationship with a new trading partner .
The EU Guidance note is in the same vein as the summary AML Alert Russia sanctions – Trade sanctions circumvention which was produced by the Accountancy AML Supervisors’ Group (AASG) from an extract from the UK Department of Business and Trade notice NTE 2023/08: Russia sanctions – Trade sanctions circumvention published 22 May 2023 . Details of this notice were brought to members attention in a news item from Professional Standards Dept. of the Institute of August 23, 2023 where they alluded to awareness of the risk and obligations in relation to sanctioned goods as an important first step for those working in the accountancy profession so that they do not become party to the trade sanctions circumvention.