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BIFA Member Guidance - UK Sanctions Against Russia

Following the recent sanctions imposed by the UK against Russia, BIFA has been contacted by Members regarding the impact on trade, stemming from the Russian invasion of the Ukraine. There are two pieces of guidance posted on the Government website which Members should be aware of and comply with.

The first which can be viewed here: https://www.gov.uk/government/publications/russia-sanctions-guidance/russia-sanctions-guidance

This covers financial, trade, shipping and immigration sanctions on Russia.  These are an update on the EU sanctions and impose a number of prohibition and requirements on trade which can be enforced by penalties. 

There are prohibitions applicable to certain categories of goods and exporters should check the regulations carefully before exporting goods to Russia. 

It would be advisable to contact the Export Control Joint Unit, https://www.gov.uk/government/organisations/export-control-organisation before shipping any goods to Russia. Members should also be careful if they suspect that goods may be shipped to one country and then either diverted or onforwarded to Russia.

The second document can be viewed at https://www.gov.uk/government/publications/financial-sanctions-ukraine-sovereignty-and-territorial-integrity. 

This details the asset freezes on those identified as being involved in destabilising the Ukraine, or undermining, threatening the territorial integrity, sovereignty and independence of the Ukraine.

This includes persons responsible for engaging in, providing support for, or promoting any policy or action that destabilises Ukraine, undermines, or threatens the territorial integrity, sovereignty and independence of Ukraine.

The other area that Members should be aware of, is the routing of cargo and whether the routing goes via or overflies Russia. Concerns have been expressed regarding some rail routes used to move goods such as the Trans-Siberian Railway, and many airlines have advised that they will no longer be flying over the Ukraine.

Members should check with their insurers regarding the impact on freight forwarder insurance and liability policies, as cover may be withdrawn and/or premiums increased for goods being shipped to/from Russia for example. 

BIFA recommends that its Members review their internal processes relating to shipments to/from Russia until the current crisis is resolved. 

Please note that BIFA can only provide generic guidance and if more specific advice is required, a suitably qualified solicitor should be consulted.

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