Russia’s invasion of Ukraine and the west’s response has magnified the importance of export compliance and due diligence, with up to 200 sanctions a day being imposed and exporters need to ensure they are compliant with the requirements of any new legislation, or risk criminal prosecution.
Many commercially available materials, products, technologies and chemicals could have an end use or properties which mean they are subject to export licences, or may be covered by end-use controls or sanctions.
Investigation of a captured Russian tank at the start of the Ukraine conflict, uncovered systems which contained British parts and further investigation discovered multiple military applications, using western technologies and now EU and UK customs are investigating how they get there and who supplied them.
The war in Ukraine has magnified the importance of export compliance and due diligence, with up to 200 sanctions a day being imposed and exporters need to ensure they are compliant with the requirements of any new legislation.
It is the exporter’s responsibility to clarify whether they need an export licence from the Export Control Joint Unit (https://www.gov.uk/government/organisations/export-control-joint-unit) and failure to obtain a licence, when one is required, or failure to observe the terms of a licence, is a criminal offence and ignorance is not an excuse.
Exporting firms need to understand the intricacies of their supply chains, including all components and in particular US parts which, even if they only form a small part of the end-product, may exceed limits that mean they can only be re-exported with authorisation from the US Department of Commerce.
The risk of getting US export compliance wrong is very expensive, with fines that have been known to run into tens of millions of dollars and potentially liberty threatening, with long jail sentences if convicted.
We have long-established experience in shipping controlled goods and while we cannot apply for your export licence, we can advise on due diligence in the UK and US, to make your export supply chains compliant.
EMAIL our export manager, Charlie Simpson for further information, or to discuss your exporting situation.