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News 06 Nov, 2025

“Countering Russian sanctions evasion” – guidance from the UK

Tony Paulson
Tony Paulson
Head of Asia & Corporate Director

The UK’s Office of Trade Sanctions Implementation or OTSI has recently published updated guidance to the freight and shipping sectors on how to avoid circumvention of sanctions against Russia.

OTSI note that this guidance is intended to:

“…help businesses in the freight and shipping sector understand Russian circumvention practices and reduce their risk of being targeted by those seeking to evade sanctions. It contains: 

  • information on the range of goods at heightened risk of being diverted to Russia 
  • suggestions for compliance best practice and enhanced due diligence procedures 
  • red flag indicators of potential sanctions evasion via circumvention 
  • additional resources to aid businesses in these sectors in managing their risk and meeting their compliance obligations”   

Members undertaking trades to or from Russia or otherwise potentially having a Russian nexus are encouraged to note the OTSI guidance, since it may be of use in designing and implementing an appropriate sanctions compliance programme to ensure that they are not exposed to sanctions enforcement measures.