The Office for the Implementation of Trade Sanctions (OTSI) has published three guides for exporters on sanctions against Russia:
1. No-Russia clause
2. Countering Russian sanctions evasion – guidance for exporters.
3. Trading under sanctions with Russia.
These guides state that some British exporters are beginning to include a clause in their contracts that restricts the buyer/importer from re-exporting goods to Russia. This clause is known as the “best practice component” at OTSI. OTSI has also published a list of items that exporters should be aware of in order to avoid violating sanctions.
These items include:
– Ordered product is incompatible with technical level of country it is being shipped to, e.g., semiconductor manufacturing equipment being shipped to country with no electronics industry.
– The customer is physically located in countries where Russia purchases from, borders with or otherwise maintains relations with.
– All communication is carried out through a representative, who apparently has general power of attorney.
OTSI, as a part of the Department for Business and Trade, was launched in October 2024. The main aim of OTSI is to strengthen the United Kingdom’s implementation and enforcement of trade sanctions.
