Expeditors Newsflash

UK Government Issues New Guidance on "No Re-Export to Russia" Clauses

Posted by Jessica Hajj on 1/16/25 5:00 PM

On January 7, 2025, the UK government issued the “No-Russia Clause Guidance” for those involved in exporting and supplying Common High Priority Items and any other items critical to Russian weapons systems and its military development. The guidance aims to support businesses in tailoring due diligence within exporter contracts and to support those wishing to insert a "no re-export to Russia" clause.

To help mitigate the risk of sanctioned items ending up in Russia, the UK Government advises exporters to insert a clause restricting the buyer/importer from re-exporting the items to Russia. Though such a clause is not required under the UK-Russia sanctions regulations, it may be considered a best practice for due diligence.

According to the Guidance, the relevant business has the discretion to determine the exact wording of a "no re-export to Russia" clause so that it best suits their needs and contract. The guidance also recommends seeking independent legal advice when drafting, negotiating, and including a "no re-export to Russia" clause in any existing or new contracts. A template created by the UK authorities is included in the guidance.

The European Union already requires EU operators to insert a "no re-export to Russia" clause into specific export contracts in accordance with Article 12g of Council Regulation (EU) No 833/2014 of July 31, 2014, concerning restrictive measures because of Russia's actions destabilizing the situation in Ukraine.

The United States Bureau of Industry and Security has also issued guidance for exporters regarding language they can include in their sales contracts or other export documents.

The “No-Russia Clause Guidance” can be found here: https://www.gov.uk/government/publications/no-russia-clause/no-russia-clause-guidance

The UK Common High Priority Items List can be found here: https://www.gov.uk/government/publications/russia-sanctions-common-high-priority-items-list/15bbaf12-a67d-40ec-94b4-a6d5499c892b

EU Article 12g of Council Regulation (EU) No 833/2014 can be found here: https://finance.ec.europa.eu/publications/no-re-export-russia-clause_en

US Bureau of Industry and Security Guidance for Exporters: https://www.bis.gov/media/documents/ru-no-russia-contract-clauses

Topics: UK, Russia

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