UK Updates Russia Sanctions Circumvention Guidance
The U.K. this week revised its Russia-related sanctions evasion guidance to update its list of countries and items that pose high risk of sanctions circumvention.
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The U.K. said companies should consider carrying out "enhanced due diligence" for transactions or customers with ties to:
- Armenia
- China, including Hong Kong and Macau
- India
- Kazakhstan
- Kyrgyzstan
- Malaysia
- Serbia
- Thailand
- Turkey
- United Arab Emirates
- Uzbekistan
- Vietnam.
It also updated its list of goods within the military, dual-use, aerospace, automotive, microelectronics and heavy machinery industries that are "at higher risk of circumvention," including:
- a wide range of industrial machinery, plant and laboratory equipment
- instruments for aeronautical and radio navigation
- motor vehicles, engines and vehicle parts
- tractors and self-propelled works trucks
- mechanical shovels, excavators and shovel loaders
- centrifugal pumps
- turbojets, gas turbines and parts
- oil lubricants
- printing inks
- paints and varnishes
- reaction initiators and catalytic preparations
- heat exchange units, industrial type
- computer monitors, processing units, semiconductor devices, electronic integrated circuits, and apparatus for manufacturing these items.