UK OTSI No Re-Export to Russia Clause


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
Products Corporate
Regions EMEA
Rule Type Guidance
Rule Date 1/7/2025
Effective Date 1/7/2025
Rule Id 239322
Linked to Rule :239320
Reg. Last Update 1/7/2025
Report Section AML & Enforcement

Last substantive update on 01/09/2025