According to press reports, the main customs office in Ulm imposed a fine of 190,000 euros on a company from Baden-Württemberg. The reason for this is that the company can use a machine for both peaceful and military purposes (so-called dual-use goods) without appropriate approval according to Russia has exported. Entrepreneurs should always check whether all necessary permits have been obtained for dual-use goods and exports relevant to sanctions.
Export of dual-use goods to Russia
In simple terms, the sanctions imposed by the European Union (EU) on Russia prohibit the export of dual-use goods to Russia if these goods are or could be intended wholly or partly for military purposes or for a military end-user. The export of dual-use goods is generally prohibited if the end user is the Russian armed forces.
Furthermore, exports of dual-use goods are subject to approval. An offence may not only have consequences in terms of criminal law or fines. Administrative sanctions, such as the revocation of customs authorisations, are also at the discretion of the authorities.
Effective compliance is mandatory
Entrepreneurs should be cautious about exports to Russia, but they should not shy away from doing business in Russia per se. With an effective compliance system, risks can be minimized and profits maximized. For example, a work instruction sensitizes your employees to check whether the necessary permits are available, especially when exporting dual-use goods.
Ask our foreign trade lawyers your questions about exporting dual-use goods now.
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