The European Commission has recently published due diligence guidance focussing on the prevention of Russian sanctions circumvention.

This short document is a useful summary of best practice that could apply to all businesses (in or out of EU) which are exposed to potential sanctions risk.  The guidance includes:

• The most helpful guidance yet on sanctions risk assessments;
• What good enhanced due diligence looks like, covering counterparties, the underlying transaction and the goods themselves; and
• Circumvention red flags.

While the guidance is aimed at EU operators and addresses Russian sanctions, the guidance contains good practice that all businesses can consider because the principles apply to global trade of all nature and will help prevent other financial crimes such as trade-based money laundering, not just sanctions circumvention.

If you would like a no-obligation discussion on how a sanctions risk assessment could support your business, then please contact us.