UK RED ALERT - exporting high-risk goods to Russia [DEC 2023]

On 06 December 2023, the UK warned of Russia attempting to circumvent sanctions to purchase restricted goods and services.

The National Crime Agency has issued an alert to financial institutions and other members of the UK-regulated sector, warning that Russia is trying to procure UK-sanctioned goods through intermediary countries.

Sanctions imposed on Russia because of its invasion of Ukraine have had a significant impact on its ability to purchase products, including military supplies, on international markets.

However, Russia uses complex supply chains and alternative supply routes to circumvent these controls to acquire sanctioned products.

The NCA has worked with HMRC, the Department for Business & Trade, the Foreign, Commonwealth & Development Office, and HM Treasury’s Office of Financial Sanctions Implementation to help the financial sector and other businesses identify potentially suspicious transactions. This included highlighting a range of red flags, such as:-

• Customers who significantly overpay for an item on the Common High Priority list,
• Transactions involving entities with little to no web presence or
• Where the item or service does not fit the purchaser’s normal line of business.

The alert has been issued to the regulated sector but will also be relevant to business sectors outside the regulated sector for anti-money laundering, in particular

• Customs brokers,
• Freight forwarders and
• Other transportation and logistics providers.

The alert is available on the NCA website (251 KB) . https://nationalcrimeagency.gov.uk/who-we-are/publications/687-necc-red-alert-exporting-high-risk-goods

Earlier this year, G7 partners announced the Enforcement Coordination Mechanism to bolster compliance and enforcement of our measures and deny Russia the benefits of access to G7 economies including the access to advanced goods, technologies and services.

The G7 called on other countries and international actors to cease providing material support to Russia's war or face severe costs.

In response, the UK, US, EU and Japan have developed a Common High Priority items list, which includes many items found on the battlefield in Ukraine and includes integrated circuits, as well as other electrical and mechanical components.

• https://www.gov.uk/government/publications/russia-sanctions-common-high-priority-items-list/russia-sanctions-common-high-priority-items-list

Items on this list are at high risk of being used in Russian sanctions circumvention efforts. UK businesses are advised to conduct additional due diligence to ensure that the end destination of these products is not Russia.

Sources

https://nationalcrimeagency.gov.uk/news/uk-warns-of-russia-attempting-to-circumvent-sanctions-to-purchase-restricted-goods-and-services

https://nationalcrimeagency.gov.uk/who-we-are/publications/687-necc-red-alert-exporting-high-risk-goods/file

https://www.gov.uk/government/publications/russia-sanctions-common-high-priority-items-list/russia-sanctions-common-high-priority-items-list