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Exporters of high priority items must implement measures to prevent sanctions circumvention
27.02.2025.

As of 26 December 2024, persons who sell, supply, transfer or export goods included in the list of high priority items must take measures to identify the risks associated with the entry of these goods into Russia and implement appropriate policies, controls and procedures to mitigate these risks. Likewise, persons must ensure that these requirements are implemented by companies established outside the European Union that they own or control.

The list of common high priority items includes goods and technologies that are important for the development or production of Russian military goods or that have been found in Russian weapons on the battlefield. The list of high priority items is available Annex XL and Annex XLVIII to Council Regulation No 833/2014 of 31 July 2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine1 (Regulation No 833/2014). For goods included in Annex XLVIII to Regulation No 833/2014, the obligation to introduce measures to prevent sanction circumvention comes into force on 26 May 20252.

These requirements are specified in Article 12gb(1) of Regulation No 833/2014 and provide that natural persons and legal persons who sell, supply, transfer or export goods included in the list of high priority items must:

  1. take appropriate steps, proportionately to their nature and size, to identify and assess the risks of exportation to Russia and exportation for use in Russia for high priority items or technology, and ensure that those risk assessments are documented and kept up-to-date;
  2. implement appropriate policies, controls and procedures, proportionately to their nature and size, to mitigate and manage effectively the risks of exportation to Russia and exportation for use in Russia for high priority items or technology, whether those risks were identified at their level or at the level of the Member State or of the Union.

The requirements do not apply to persons who sell, supply or transfer items only within the European Union or to partner countries listed in Annex VIII to Regulation No 833/2014.

Similar requirements for exporters of high priority items are also specified in Council Regulation (EC) No 765/2006 of 18 May 2006 concerning restrictive measures in view of the situation in Belarus and the involvement of Belarus in the Russian aggression against Ukraine3.

A more detailed explanation of the requirements for exporters of high priority items is available in the frequently asked questions document published by the European Commission, available here.

Please note that the Financial Intelligence Unit (FIU) is currently developing guidelines for business operators for the implementation of an internal control system, which will, inter alia, explain the measures that exporters of high priority items must implement to identify, manage and mitigate the risks of sanctions circumvention to ensure compliance with the requirements imposed on them. The guidelines will be published on the FIU website.

1The consolidated version is available here: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A02014R0833-20241217&qid=1740390623098

2Council Regulation (EU) 2025/395 of 24 February 2025 amending Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine; available here: https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=OJ:L_202500395

3The consolidated version is available here: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A02006R0765-20241216&qid=1740396235868

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