UK Guidance on Countering Sanctions Evasion
Question: Why Israeli companies may be subject to higher scrutiny by their UK partners?
Answer: In January 2025, UK Office of Trade Sanctions Implementation issued a new guidance supporting exporters and manufacturers in identifying Russian evasion practices and developing strategies to mitigate the risk of their goods becoming targets of circumvention. The guidance aims at protecting technology from misappropriation and preventing the financial and reputational harm which could arise from engaging in sanctioned trade. While this guidance is specific to trade sanctions targeting Russia, the same advice maybe generally applied to other UK sanctions regimes.
The guidance identifies goods that are at higher risk of circumvention (including a wide range of industrial machinery, plant and laboratory equipment, printing inks, computer monitors, processing units, semiconductor devices, and electronic integrated circuits)and sectors that are generally more exposed to sanctions circumvention(including military and dual use goods, aerospace, automotive, microelectronics, and heavy machinery). In addition, the guidance highlights the role that entities in third countries play in sanctions circumvention through re-export and urges to conduct enhanced due diligence when the listed products are exported to certain third countries.
The list of such third countries includes Israel (alongside China, India, Turkey, UAE and others),which means that any Israeli company purchasing the goods identified in the guidance from a UK company may be subject to enhanced due diligence. Israeli companies should be prepared to respond to the requisite due diligence requests and provide information on their sanctions compliance programs, details of re-export destinations, if any, the product’s end-user and end-use, full ownership and control structure and other relevant information. You may also expect that a no export to Russia clause will be added to your contract.
*The contents of this message, current at the date of publication, are for reference and general informational purposes only and do not constitute legal advice. You should contact your attorney to obtain advice with respect to any particular legal matter. You should not act or refrain from acting on the basis of information in this publication without first seeking legal advice from counsel in the relevant jurisdiction. Only your individual attorney can provide assurances that the information contained herein – and your interpretation of it – is applicable or appropriate to your particular situation.
Question: Why Israeli companies may be subject to higher scrutiny by their UK partners?
Answer: In January 2025, UK Office of Trade Sanctions Implementation issued a new guidance supporting exporters and manufacturers in identifying Russian evasion practices and developing strategies to mitigate the risk of their goods becoming targets of circumvention. The guidance aims at protecting technology from misappropriation and preventing the financial and reputational harm which could arise from engaging in sanctioned trade. While this guidance is specific to trade sanctions targeting Russia, the same advice maybe generally applied to other UK sanctions regimes.
The guidance identifies goods that are at higher risk of circumvention (including a wide range of industrial machinery, plant and laboratory equipment, printing inks, computer monitors, processing units, semiconductor devices, and electronic integrated circuits)and sectors that are generally more exposed to sanctions circumvention(including military and dual use goods, aerospace, automotive, microelectronics, and heavy machinery). In addition, the guidance highlights the role that entities in third countries play in sanctions circumvention through re-export and urges to conduct enhanced due diligence when the listed products are exported to certain third countries.
The list of such third countries includes Israel (alongside China, India, Turkey, UAE and others),which means that any Israeli company purchasing the goods identified in the guidance from a UK company may be subject to enhanced due diligence. Israeli companies should be prepared to respond to the requisite due diligence requests and provide information on their sanctions compliance programs, details of re-export destinations, if any, the product’s end-user and end-use, full ownership and control structure and other relevant information. You may also expect that a no export to Russia clause will be added to your contract.
*The contents of this message, current at the date of publication, are for reference and general informational purposes only and do not constitute legal advice. You should contact your attorney to obtain advice with respect to any particular legal matter. You should not act or refrain from acting on the basis of information in this publication without first seeking legal advice from counsel in the relevant jurisdiction. Only your individual attorney can provide assurances that the information contained herein – and your interpretation of it – is applicable or appropriate to your particular situation.
