UK OTSI No Re-Export to Russia Clause

Published on: Jan 9, 2025

On Jan. 7, UK OTSI issued guidance for exporters on no-Russia clause.

  • UK GVT, OTSI issued guidance to support businesses in tailoring due diligence within exporter contracts and support those wishing to insert a no re-export to Russia clause.
  • On same day UK OTSI issued guidance on countering sanctions evasion, see #239320.
  • Summary
  • Guidance is for those involved in export and making available of common high priority items and other items critical to Russian weapons systems and military development.
  • Contractual clauses prohibiting buyers/importers from re-export, or export from a third country, of items subject to Russia sanctions could help protect you as a seller.
  • While UK GVT does not require it, including such clauses in export documents could help mitigate risk of being inadvertently involved in a customer's breach of sanctions.
Regulators
UK GVT; UK OTSI
Entity Types
Corp
Reference
Gd, 1/7/2025
Functions
AML; Compliance; Financial; Legal; Operations; Reporting; Sanctions
Countries
Russia; United Kingdom; Cross-Border
Category
Central Government
State
N/A
Products
Corporate
Rule Type
Guidance
Regions
EMEA
Rule Date
Jan 7, 2025
Effective Date
Jan 7, 2025
Rule ID
239322
Linked to
Reg. Last Update
Jan 7, 2025
Report Section
AML & Enforcement