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Writer's pictureJeff Gunn

Due Diligence

When to Conduct Due Diligence


Last year we discussed how the EU was tightening and enforcing Trade Sanctions against Russia, since then the UK Government has been constantly issuing new sanctions against Russian; Trade, Businesses and Individuals. Exporters need to be keeping up to date with these new sanction measures and adjusting their business accordingly.



Trade sanctions are used as a political tool to restrict or prohibit trade with a particular country or entity in order to achieve specific goals, such as promoting human rights, preventing the spread of weapons, or punishing countries that engage in harmful activities. The ultimate aim of trade sanctions is to bring about change in the targeted country's behaviour.


Sanctions against Russian Organisations and Persons have been ongoing and increasing since the invasion of Ukraine in February 2022. The UK issues a Guidance and Regulations on Russian Sanctions and listing controlled items by Commodity Code.


As mentioned in our previous blogs, Russia is seeking to procure restricted goods such as those on this list, via non-sanctioning countries. Businesses should ensure that they consider these risks. Businesses should undertake due diligence to ensure that the end destination of these products is not Russia. As an exporter of goods you should consistently exercise your due diligence processes and asses the risk of diversion of the goods you are exporting. This is not a one-off process, as previously mentioned the sanction environment is highly dynamic and due dilligence checks should be conducted throughout the Marketing, Sales and Delivery phases of your business.


At Ceterus Consultants we deliver consultancy in Business Management, Quality Assurance and Export Controls. Our services and rates are tailored to customers requirements.

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