Russia sanctions: Risks for freight forwarders

With effect from 1 August 2014, the European Union (EU) has adopted comprehensive economic sanctions against the Russian Federation. These include an arms embargo, capital market measures and export bans on equipment for the energy sector and so-called dual-use goods, i.e. goods that can be used for both civil and military purposes. In addition, 20 organisations and 87 people are now on”black lists”.

In Russia, particular caution is required for freight forwarders and carriers. In fast business transactions, they can usually only rely on the information from the bills of lading and details of their business partners without being able to verify their truthfulness. Here, there is a quick way to disguise the intended use of a good, the origin or the destination of a good in order to circumvent the sanctions. For example, the people on the”black lists” could use straw men.

The unsuspecting freight forwarders are threatened with investigations under at least fines or even criminal law. By inducing or actually carrying out the transport of dual-use goods, it is they who actually carry out the sanctioned act. The same applies to indirect services to listed persons, even if the freight forwarder or carrier does not recognize this at all. Negligence is another way in which these companies and their employees participate in circumventing European sanctions.

We are happy to assist you with our experience in customs fines and criminal matters!

 

Lawyer Dr. Tristan Wegner

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