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UK Updates Guidance on Russia-Related Export Control Diversion

The U.K. updated its Russia-related export control and sanctions guidance this week to provide more information on license requirements for common high-priority list items destined for Russia.

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The guidance, which includes new information in Section 6, says the U.K. will issue export license applications for those items on a case-by-case basis and will deny applications if there is a “risk the items will be diverted to an undesirable end-user or for an undesirable end-use.” The U.K. also said it “considers the risk of re-export of the items to undesirable destinations when assessing the risk of diversion,” which includes an assessment of whether the recipient country has tools in place to “exert effective export controls.”

The government “will be minded to refuse applications with uncertain end-use or end-user (such as items for stock), where it assess[es] there’s a risk of diversion to Russia.”