Overview
Partner Alexandra Melia authored an article published by Law360 titled, "Key Points From Trade Sanctions Office 'No-Russia' Guidance." The article discusses the UK Office of Trade Sanctions Implementation's (OTSI) publication of new guidance documents on no-Russia clauses and countering Russian sanctions evasion. The no-Russia clause guidance helps exporters prevent reexporting products to Russia, particularly those critical to Russian military systems. The sanctions evasion guidance aids in identifying and mitigating risks associated with Russian circumvention efforts. Following Russia's invasion of Ukraine, the UK imposed sanctions leading to indirect procurement attempts by Russia. OTSI advises businesses to enhance due diligence, monitor supply chains, and implement robust trade compliance programs to align with the new guidance and mitigate sanctions evasion risks.