European Commission guidance on Russia sanction circumvention

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The European Commission has published guidance for EU operators on implementing enhanced due diligence to shield against Russia sanctions circumvention.

Guidance is provided on:

  • Risk assessment of possible sanctions circumvention;
  • Enhanced due diligence; and
  • Circumvention red flags related to business partners and customers.

Firms should view the European Commission’s guidance and take any appropriate action.

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