ARTICLE
30 September 2024

G7 Publishes First Ever Joint Guidance On Preventing Evasion Of Export Controls And Sanctions Imposed On Russia

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Buchanan Ingersoll & Rooney PC

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With 450 attorneys and government relations professionals across 15 offices, Buchanan Ingersoll & Rooney provides progressive legal, business, regulatory and government relations advice to protect, defend and advance our clients’ businesses. We service a wide range of clients, with deep experience in the finance, energy, healthcare and life sciences industries.
On September 24, 2024, the Group of 7 Countries published joint guidance for industry on prevention of evasion of the export controls and sanctions imposed on Russia since its war on Ukraine in February 2022.
Worldwide International Law

On September 24, 2024, the Group of 7 Countries (the United States, Canada, France, Germany, Italy, Japan, the United Kingdom, and the European Union) published joint guidance for industry on prevention of evasion of the export controls and sanctions imposed on Russia since its war on Ukraine in February 2022. Since February 2022, the G7 and other members of the Global Export Control Coalition (GECC) have implemented unprecedented multilateral sanctions and export controls that restrict Russia's access to technologies and other sensitive articles it needs to further its illegal war in Ukraine. Last year, the G7 created a sub-working group on export control enforcement to support the exchange of information, including through the issuance of coordinated guidance.

The guidance highlights preventing the diversion of controlled items to Russia, including through third countries, and provides best practices in identifying Russian sanctions evasion tactics. The guidance document includes: (1) a list of items which pose a heightened risk of being diverted to Russia (i.e. integrated circuits); (2) updated red flag indicators of potential export control and/or sanctions evasion; (3) best practices for industry to address these red flags; and (4) screening tools and resources to assist with due diligence. Click here to view the full guidance document: https://www.bis.gov/press-release/g7-announces-industry-guidance-preventing-evasion-export-controls-and-sanctions.

As Russian sanctions evasion tactics continue to evolve, this guidance aims to assist industry in complying with multilateral export controls and sanctions, mitigating risk and exposure to liability, and preventing reputational harm.

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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