The Corporate Crime Observatory is thankful to our Head of Economic Sanctions, Dr. Damien Romestant, for bringing this relevant topic to everybody's attention.
The European Union's Commission has updated its list of frequently asked questions and answers related to the economic sanction regime imposed because of the Russian invasion of Ukraine. It is possible to highlight that one of the challenges exporters and compliance officers have to face is to determine whether or not their goods are falling into the scope of the sanctions.
This duty is even much more complicated when it comes to dual-use goods (i.e., items that can be used both for civilian and military applications). In that regard, the European Union's Commission specifies that a complementary technical assessment might be required to fully determine if the goods can, or not, be exported. Although the export of these items has been prohibited since 2014, the prohibition now applies "even when these items are intended for civilian end-users or uses, with very limited exemptions and derogations."
Also, the Sanctions Regulation "prohibits the export of additional ‘Advanced Technology’ items to limit the enhancement of Russia’s military and technological capacity" in sectors such as electronics, computers, telecommunications, information security, sensors and lasers marine, and chemicals.
The European Union has published a list of very useful frequently asked questions on its website that has been updated last time on Oct. 10, 2022.
You may access the FREQUENTLY ASKED QUESTIONS (updated Oct. 10, 2022) at the following link: https://finance.ec.europa.eu/system/files/2022-10/faqs-sanctions-russia-export-related-restrictions-russia_en.pdf