EU Releases Guidance on Preventing Circumvention of Russia Sanctions
The European Commission released a general guidance document on implementing due diligence practices to halt the circumvention of the sanctions on Russia. The guidance includes risk assessment of possible sanctions circumvention, due diligence best practices, circumvention red flags related to…
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business partners and buyers, and EU sanctions whistleblower tools. The due diligence best practices section addresses the stakeholder and transaction levels and the level of the goods themselves.