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.

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.