Key takeaways
UK issues guidance to combat sanctions evasion
Freight sector urged to strengthen compliance measures.
Enhanced due diligence now a business imperative
Verify customers, cargo, and documentation to reduce risk.
Spot red flags before they become liabilities
Learn indicators of suspicious shipments and transactions.
On 3 November 2025, the UK Department of Business and Trade (DBT) and the UK Office of Trade Sanctions Implementation (OTSI) published guidance for the freight and shipping sector aimed at helping the sector to better understand the circumvention practices used by Russia to evade sanctions.
The guidance is intended to be for freight forwarders, carriers, hauliers, customs intermediaries, postal and express operators, and other companies facilitating the movement of goods. The objective of the guidance is to reduce the risk that these key stakeholders in the freight and shipping industry will be targeted by entities and individuals seeking to evade sanctions.
The guidance recognises that freight is a crucial service in transporting or facilitating the transport of goods. Therefore, the compliance and due diligence exercised by operators in the freight sector can help to prevent Russia from circumventing UK sanctions and accessing the goods it requires to continue the war against Ukraine.
Whilst the guidance is directed at preventing Russian sanctions evasion, much of the content is equally applicable to the UK’s other sanctions regimes e.g. against Iran, Belarus and North Korea.
Significantly, the guidance was developed in conjunction with industry. It is primarily focused on goods exports, but some aspects may also be applicable to imports.
The guidance is crucial reading for those in the freight and shipping sector. It can be found here.
The guidance supplements the Government’s circumvention guidance for business, which also addresses exports.
This article highlights some key recommendations offered in the guidance.
Overview
The guidance contains:
information on the range of goods at particular risk of being diverted to Russia;
recommendations for compliance best practice and enhanced due diligence procedures;
red flag indicators of potential sanctions evasion via circumvention; and
additional resources to aid businesses in managing their risk and meeting their compliance obligations.
Responsibility and liability
The guidance stresses that all businesses operating in the UK freight and shipping sector should be aware of the countries and types of goods to which trade sanctions apply, and the types of activities which could be in breach of sanctions. Companies are expected to undertake due diligence to ensure that each consignment they handle or process complies with sanctions.
UK businesses are responsible for fully determining the extent of their specific sanctions risk exposure and are advised to develop an appropriate set of safeguards and controls to mitigate the risk of facilitating Russia’s access to sanctioned goods.
The guidance also highlights that it is a criminal offence for a UK individual or business to engage in or facilitate trade that is prohibited under sanctions, or to intentionally participate in activities knowing that the object or effect of them (whether directly or indirectly) is to circumvent, enable, or facilitate the circumvention of sanctions. Additionally, any person or business who knowingly or recklessly provides untrue information to a customs officer may be held criminally liable.
Due diligence best practice
The guidance covers relevant considerations relating to “know your customer, know your cargo.”
As to know your customer, the advice is among other things to:
conduct background checks to verify the identities of the shipper and consignee
check whether these companies or their directors have been designated on the UK Sanctions List
repeat due diligence at regular intervals to ensure that the risk has not changed
look for irregularities in shipper’s requests that are different from normal business
ask the shipper whether it has conducted a sanctions risk assessment on the export
add sanctions-specific clauses to general terms and conditions and contracts of carriage
seek independent legal advice when considering a “no re-export to Russia” clause for inclusion in any new or existing contract.
As to know your cargo:
If you handle the paperwork:
check whether sanctions apply to the shipment
check the paperwork carefully for accuracy and authenticity
ensure customer has appropriate certifications and licences in place before export
check that the correct commodity code and an accurate description of the goods has been given
include comprehensive information in the packing list and ensure that it is correct
include serial numbers, if any, in the goods description
confirm that the language used in the export paperwork and package labels is consistent with the stated destination
check that the information in all the different paperwork is consistent
If you handle the cargo:
check the cargo against the paperwork on receipt of the consignment
where possible, inspect the consignment to verify its contents
use tamper-evident seals and keep consignments secure at all stages of transit
ensure that the details on the consignment’s labels correspond with the details in the commercial invoice
upon delivery, check the information in the bill of lading matches the information in the documentation
The guidance cautions against handling blind shipment requests except from trusted partners or parties that have been independently verified. It also advises care in issuing switch bills, including ensuring that any replacement documentation provides accurate descriptions and correct quantities for goods.
Red flags
While the guidance for businesses provides a list of red flag indicators of potential sanctions circumvention, this guidance highlights a set of indicators specific to the freight and shipping sector.
However, the guidance makes clear that no single red flag is definitively indicative of illicit activity and transactions should be assessed holistically as part of a thorough due diligence process.
The red flag indicators to which attention is drawn in this guidance are:
Contents of consignment
For example:
consignment contains sanctioned goods, especially those with military or dual-use applications
product’s capabilities do not fit in with consignee’s line of business
product shipped in unusual or inconsistent qualities
vague or dubious description of goods in accompanying documentation
shipper takes steps to conceal true contents of consignment e.g. it makes unusual requests regarding packaging, labelling or removing other documentation
shipper obstructs ability to check contents of or to inspect consignment
Export destination
For example:
destination country has weak import/export control laws
consignment due to be transhipped through country for which additional due diligence is suggested
destination country is actively engaged with sanctioned country
destination country shares border with Russia
shipper requests specific route that does not align with normal practice
consignee’s delivery address is anomalous or inappropriate to receive the type of goods in question
Customer
For example:
transaction involves multiple parties based in third countries without a clear rationale
shipper or their representative uses webmail instead of corporate domain-based email account
inability to verify identity or key information regarding shipper
last minute changes to parties involved in the transaction from a Russian entity to an entity in another country
Transaction
For example:
false, inaccurate or incomplete documentation with vague information
inconsistencies in the information provided across the documentation
description of the goods is misleading or non-specific
client prepared to pay significantly over the market rate for the shipping process
documentation is in Russian or is in language that is not consistent with stated destination
requests to use non-standard payment route
payment for services unexpectedly comes from third country, bank account or business not otherwise involved in transaction or listed in the paperwork
any indications that documentation may be fraudulent
Imports
The guidance also states that companies should be aware of the range of Russian-origin goods sanctioned for import into the UK. Sanctions on certain products also apply where they have been subsequently processed in a third country and have lost their Russian-origin status.
Comment
The guidance is a very useful and helpful aid for the freight and shipping sector. It remains crucial for operators in the sector to ensure that they are familiar with applicable sanctions regulations and the Sanctions List.
In the event of any suspicion that sanctions may have been inadvertently breached, the suspected breach should be reported to DBT/OTSI.
In the event of any concern that a particular transaction or shipment may risk breaching trade sanctions, legal advice should be taken without delay.
