One thousand four hundred traders, 82% of whom reported that they traded with Russia, attended a recent webinar organised by the Institute of Export & International Trade (IOE&IT) on How to comply with trade sanctions against Russia.
IOE&IT trade specialist Ray Burgin set out eight practical steps that companies could take to make sure that they were trading compliantly: know your product; know your product’s destination; know your customer; know your supplier; revisit your licences; revisit your contracts; run an internal compliance programme; and communicate with your agents.
The webinar also heard from the Department for International Trade’s Director for Exports, Paul McComb, who outlined the Government’s thinking and told them how to make use of the Export Support Service to access the latest information and advice. There was insight into the possible effects on UK trade with Russia from Rebecca Harding, CEO of Coriolis Technologies, and author of the book The Weaponization of Trade. She drew attention to the effect that sanctions imposed after Russia’s illegal annexation of Crimea had on the UK’s services trade with Russia, which plummeted as a result.
The IOE&IT’s director general, Marco Forgione said:
Of course in time of war, trade takes second place to our concern for the human suffering.
“It is heartening that so many British businesses took the time to learn more about how to comply with these sanctions. They want to make sure that they are not inadvertently breaking the law.”
There are many examples of how companies could be caught out. Dual use goods are not always obvious; there are around 3,000 tariff codes to which dual use has been allocated, from temperature control systems to fuel pump covers, so it is really important that exporters really know their products and understand where they fit.
“And it’s not just the goods it can be the packaging which is a problematic. A cider manufacturer recently had problems with their exports because the vats they were using to transport the cider could be re-used to transport banned goods.
“Just as important is that exporters understand who the end user of their product is going to be. In complex supply chains that entity may be at some removed from the customer, so exporters need to be sure that they are not dealing with someone acting on behalf of a sanctioned recipient. For instance, selling to a distributor the UK business needs to be certain that their goods are not being forward sold into Russia.
“Another area of concern is the inadvertent export of Intellectual Property over the internet. Most companies would understand that sending a copy of complex designs to Russia would be an export but how many would know that even discussing them over a Zoom call could also be breaking sanctions?
“Ultimately we want to help exporters do the right thing. The IOE&IT is committed to continuing to hold dissemination events like today’s, our helpdesk is available for members who have complex queries and we can provide consultancy services to business to help them stay compliant.”