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Sanctions Againts Russia: Triangulations And Intermediations – Export Controls & Trade & Investment Sanctions

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The sanctioning measures adopted against Russia and Belarus ban
the direct or indirect import or export of certain goods, as well
as the knowingly also intentionally participation, in activities
aimed at circumventing such prohibitions.

The European Union has recently issued a notice (2022/C 145
I/01) to economic operators clarifying the sanctioning measures

In particular, with this notice, the European Union is targeting
cases of triangulation of supplies and advising Community economic
operators to take adequate due diligence measures aimed at
preventing circumvention of the sanctioning measures:

  1. through exports to third
     from where such goods can be resold in
    Russia and Belarus, such as the countries of the Eurasian Economic
    Union (EAEU composed, in addition to Russia and Belarus, of
    Armenia, Kazakhstan and Kyrgyzstan), in view of the fact that goods
    imported into any one EAEU state are in free circulation throughout
    all other EAEU states;

  2. through imports from third
     from where goods can be diverted to the EU,
    in particular when such countries do not apply restrictions on
    imports from Russia and Belarus, such as the above-mentioned EAEU
    countries, Turkey and China.

To this end, it is advisable to introduce specific statements
and/or safeguard clauses in contracts, such as:

  • statements to specify that the imported or exported goods are
    not covered by the restrictions;

  • statements acknowledging that compliance with EU sanctions
    regulations is an essential element of the contract, the breach of
    which entails the immediate termination of the same and/or possible
    compensation for damages;

  • clauses committing the importer located in third countries not
    to resell the goods under reference in Russia or Belarus and/or to
    resell such goods only to third parties who expressly undertake not
    to (re-)export the same to Russia or Belarus.

Originally Published 06 May 2022

The content of this article is intended to provide a general
guide to the subject matter. Specialist advice should be sought
about your specific circumstances.

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