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Sanctions checklist for exporters

A) Check whether the export destination country is subject to any sanctions

Export restrictions must also be observed when products are exported to a sanctioned country via a third country.

In addition, it should be noted that the provision of information related to technology or products which are subject to export restrictions could also be prohibited regardless of where the provision of information takes place, if the recipient is a person residing in a sanctioned country or a company registered in such country, or if the information is intended for use in such country.

B) Check whether the export of your products is restricted by sanctions

If products are being exported to a country targeted by sanctions, the next thing to check is whether the exported product is subject to any restrictions.

All sanctions regimes are different, and detailed information on restrictive measures targeted at specific countries is only available from the regulations of the EU Council and the specifications annexed to these regulations.

Export companies are usually the best experts on their own products: in the first instance, businesses should determine independently whether their products are subject to restrictions and if so, fully or partially.

Assistance for interpreting the regulations, if needed, is available from the Foreign Ministry, but the exporter is ultimately responsible for the legality of its export operations.

C) Ensure that your business transaction does not involve persons or entities named on a sanctions list

If the export of the products in question is not subject to prohibitions by sanctions, continue to check whether your business partner who is based in a sanctioned country, or other individuals and entities who are party to the commercial activity, are designated on the sanctions list.

The list of designated individuals and entities is annexed to the sanctions regulation in question. Any commercial activity with individuals named on the list must be refused, and any transactions which have already commenced must be halted immediately.

Designated persons and entities must also not be used for other services, such as transport, financial or banking services.

The transfer of any funds or resources to designated individuals and entities, whether directly or indirectly, is prohibited. In other words, export is also prohibited in cases where the goods, technology or know-how being exported would end up being used or exploited by a designated person or through an intermediary.

For example, an assets is considered to have been made indirectly available where a company presenting itself as a customer is in fact acting on behalf of a designated person or entity in order to obtain goods from the EU. The risk is particularly high if a foreign buyer is owned or controlled by a listed person or entity.

D) Ensure compliance with other legislation

In the case of defence materiel, dual-use goods and commercial export of firearms and ammunitions intended for civilian use, exports require authorisation regardless of whether sanctions apply.

Know your product. Know your customer. Know the legislation.

This document

Content administrator Unit for Public International Law

Updated 8/2/2016

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