Guidance

Countering Russian sanctions evasion: guidance for the freight and shipping sector

Published 3 November 2025

For freight forwarders, carriers, hauliers, customs intermediaries, postal and express operators, and other companies facilitating the movement of goods.

Foreword 

This guidance is intended to help businesses in the freight and shipping sector understand Russian circumvention practices and reduce their risk of being targeted by those seeking to evade sanctions.  

Freight is a crucial service, and you may spot attempts to circumvent sanctions when transporting or facilitating the transport of goods. Reducing Russia’s capacity to prolong the war in Ukraine is a key strategic UK objective. Your compliance and due diligence can help prevent Russia’s ability to circumvent our sanctions and access the goods it needs to conduct its war against the people of Ukraine. 

This document contains: 

• information on the range of goods at heightened risk of being diverted to Russia 

• suggestions for compliance best practice and enhanced due diligence procedures 

• red flag indicators of potential sanctions evasion via circumvention 

• additional resources to aid businesses in managing their risk and meeting their compliance obligations 

This document has been developed in conjunction with industry. It is supplementary to our circumvention guidance for businesses, where you can find additional information and advice regarding exports.  

This guidance is primarily focused on goods exports, but some aspects are also applicable to imports. 

Disclaimer 

While every effort has been made to ensure the accuracy of the information in this guidance, it does not constitute legal advice and cannot be relied upon as such.

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. 

All businesses operating in the 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 should undertake due diligence to ensure that each consignment they handle or process complies with sanctions. 

It is the responsibility of UK businesses to fully determine the extent of their specific sanctions risk exposure, and to develop an appropriate set of safeguards and controls to mitigate the risk of facilitating Russia’s access to sanctioned goods.   

Consulting the external screening databases indicated in this document is not in itself a defence if you are found to have facilitated the contravention of sanctions against Russia.   

If you are unclear about any aspect of the Regulations, in particular about whether action you are considering could contravene the Regulations, you are advised to seek independent legal advice. 

This guidance is specific to trade sanctions targeting Russia, but much of the advice applies to other countries where the UK government has imposed trade sanctions, including Belarus, Iran, and North Korea. A full list of UK sanctions regimes is available on GOV.UK. 

1. Due diligence best practice for the freight and shipping sector

Know your customer, know your cargo 

It is essential to stay up to date with any amendments to The Russia (Sanctions) (EU Exit) Regulations 2019, and to consider how any additions and changes affect your business’s compliance obligations. The UK Sanctions List should also be regularly reviewed to ensure business arrangements involving any designated persons or entities are terminated.  

Decision-making processes should take account of the risks associated with sanctions. When a business identifies a sanctions risk, it should promptly take steps to fully address that risk. This could include conducting your own research, requesting further information from the entity, and taking legal advice if unsure about your obligations.  

It is advisable to undertake a strategic risk assessment and to implement controls tailored to the operating model of your business.  

While there is no one size fits all approach, some suggestions are outlined below to assist companies in reducing their risk of facilitating the diversion of sanctioned goods to Russia. Some of these suggestions will be more relevant to your business than others. We recommend that you consider incorporating these suggestions into your internal compliance processes as appropriate within the context of your business operations. 

Information on goods at increased risk of circumvention and on third countries for which additional due diligence is advised can be found in section 2 of Countering Russian sanctions evasion – guidance for businesses. Enhanced due diligence screening should most heavily target transactions that meet these criteria. 

1.1 Know your customer: pre-screening and contracts of carriage

1. Where possible, conduct background checks to verify the identities of the shipper and consignee. A non-exhaustive checklist for screening a customer or trading partner can be found in section 3.2 of the circumvention guidance for businesses. Additional third-party screening tools to aid with customer due diligence can be found in section 4.3 of the circumvention guidance for businesses.  

2. Check whether the shipper, consignee, or known directors of these entities have been designated on the UK Sanctions List.   

3. Even with established trading partners, due diligence should be repeated at intervals to ensure that the risk has not changed. For example, a change of directors, organisational status, or transactional patterns may indicate a more significant shift in a customer’s business operations. 

4. Look out for any irregularities in the shipper’s request that stand out to you as being different from normal business.  

5. Consider requesting confirmation from the shipper that they have conducted a sanctions risk assessment on the export, and that they have taken the necessary steps to ensure that their supply chain is not involved in prohibited activity. It remains your responsibility to conduct your own due diligence on transactions you engage in. 

6. Consider adding sanctions-specific clauses to your trading conditions and contracts of carriage. These could take the form of asking the shipper to confirm that they have no knowledge or intention of facilitating the onward transit of sanctioned goods to Russia, or that they have conducted due diligence checks on the export and consignee. Including these in your export documents, alongside other due diligence steps, could reduce the risk that your customer involves you in what may be deemed a breach of sanctions.  

7. Please see guidance on the ‘no re-export to Russia’ clause for further information. It is advisable to seek independent legal advice when drafting, negotiating and including a “no re-export to Russia” clause into any existing or new contacts. 

1.2 Know your cargo: screening consignments 

Insofar as this is possible in the context of your business model, care should be taken to check and confirm the contents of the consignments you receive from customers.  

If you handle the paperwork 

1. As a first step, check whether sanctions apply to the shipment. A full list of UK sanctions regimes is available on GOV.UK. 

2. If applicable, ensure that your customer has the appropriate certifications and licences in place before the goods are exported. See more information on licensing and controlled goods. 

3. Check paperwork thoroughly to ensure it is authentic, complete, and that information is accurate. Look out for any inconsistencies, anomalies, missing, or vague information which might indicate falsification. There is no single indicator of circumvention, and each transaction should be assessed holistically. Information should be consistent across all documents. 

4. Confirm that the language used in export paperwork and package labels is consistent with the stated destination. Look out for inconsistencies, for example, if paperwork or labels are written in Cyrillic, but the goods are destined for a country which doesn’t use the Cyrillic alphabet. 

5. Check that the correct commodity code and an accurate description of the goods have been provided, and the code and description used correspond to each other.  

6. Where this information is available, include the serial numbers of goods in the ‘goods description’ sections of customs declarations and other relevant documentation.  

7. Where possible, packing lists should contain commodity codes and a clear description of each item within the consignment, the number of items and boxes, packaging details (including packaging type, weight & dimensions for each box and for the consignment as a whole), and any reference numbers used to identify boxes/cartons. Details should match those on the commercial invoice and other documentation. If information provided in the packing list is vague, ask the shipper to provide further details. 

If you handle the goods 

1. Check the cargo against paperwork on receipt of the consignment. Check that the consignment (weight, dimensions, packaging type) matches the details declared on the itemised packing list and other documentation, and aligns with what you would usually expect for that product.  

2. Where possible, inspect the consignment to verify its contents if: (1) transporting a sanctioned good identified as being at increased risk of circumvention in section 2 of the guidance for businesses; and/or (2) other risk factors concerning the transaction have been identified (including any combination of the ‘red flag’ indicators listed below). 

3. Ensure that the name and address details on the consignment’s labels correspond to the consignee details provided on the commercial invoice. 

4. Use tamper-evident seals, and keep consignments secure at all stages of transit. During shipping, look out for any signs of damage or interference or discrepancies in quantity, weight, or packaging. Ensure that the consignment is complete and intact upon delivery. 

5. Upon delivery, check that the information contained in the Bill of Lading (or equivalent) handed over by the consignee matches the information provided in your copies of the documentation. 

1.3 Blind shipments and switch bills: pre-screening and contracts of carriage

1. Incorporate an awareness of diversion risks into your standard procedures for handling blind shipments. 

2. It is advisable to only accept blind shipment requests from trusted partners or parties you have independently verified. 

3. Look out for enquiries from third party intermediaries wanting to arrange a transaction in which the identity of the consignee is hidden from the original supplier or exporter. Verify that the reason for using blind shipping procedures is legitimate, and not for the purpose of facilitating the diversion of goods to a sanctioned country, individual, entity, or shell company. 

4. Assess whether it may be unusual to ship the goods in question via blind shipping methods (for example, specialised manufacturing parts), and look out for any discrepancies or anomalies which may suggest the request is unusual or a tactic for concealing diversion. 

5. If you are asked to produce altered copies of the Bill of Lading (also known as a ‘switch bill’) for the ‘blind’ party, ensure that all documentation aligns with your understanding of the shipment process and the identities of the parties involved in the transaction. Ensure that any replacement documentation provides accurate descriptions and correct quantities for goods. 

6. When shipping via standard (non-blind) methods, look out for any characteristics of a blind shipment (for example, requests to change paperwork or labels during transit) which were not detailed in the original transport arrangements, and which the original exporter may not be aware of. 

2. Circumvention red flags  

In addition to the list of red flag indicators of potential circumvention provided in the guidance for businesses, please see below for a set of indicators specific to the freight and shipping sector. 

We encourage industry to use these indicators to guide tailored due diligence on customers and transactions, and to be alert for other possible indicators not listed below.  

No single red flag is definitively indicative of illicit activity and transactions should be assessed holistically as part of a thorough due diligence process.  

2.1 Contents of the consignment  

1. The consignment contains sanctioned goods, especially those with military or dual-use applications, or any other items flagged as being at increased risk of circumvention in section 2 of the guidance for businesses.  

2. The consignment contains goods classified under Harmonised System (HS) codes or descriptions similar or adjacent to those used to classify higher-risk goods. Goods may be misclassified to conceal a shipment which should be subject to sanctions and/or more stringent export controls, especially if the items are of a similar size and weight when packed. 

3. The product’s capabilities do not fit the consignee’s line of business, for example, an order of sophisticated computers shipped to a small bakery. 

4. The product is shipped in quantities which appear unusual or inconsistent with what you would normally expect for that product. This may include multiple shipments of smaller quantities in order to remain under export control limits or value thresholds for customs charges. 

5. The shipper has used vague or dubious descriptions of the goods in accompanying documentation (for example, ‘spare parts’, ‘samples’, ‘electrical goods’). Whilst this may be common in some contexts, it may also indicate an attempt to conceal the true contents of the consignment. 

6. The shipper makes unusual requests regarding packaging, labelling, or removing documentation, or takes other steps to disguise the contents prior to shipping.  

7. The consignment’s dimensions or weight do not align with what you would normally expect from the product, quantities, and packaging stated in the export declaration, packing list, or other documentation. 

8. The language used on package labels is not consistent with the stated destination, for example, the consignment is destined for Turkey, but package labels are written in the Cyrillic alphabet. 

9. The shipper refuses or seeks to hinder your ability to check the contents of the consignment. Reluctance to allow inspection and/or a general lack of transparency about the cargo could indicate an attempt to conceal its true nature. 

2.2 Export destination 

1. Additional due diligence is suggested for shipments to the destination country (as outlined in section 2.3 of the guidance for businesses), or the destination country is actively engaged with a sanctioned country (for example via trading links).  

2. The consignment is due to be transhipped through a country for which additional due diligence is suggested. 

3. The destination country has weak import and/or export control laws, or weak enforcement of those laws.  

4. The shipment is due to be transported through Russia to a final destination elsewhere. 

5. The destination country shares a border with Russia. Any country that shares a land border with (and has not imposed sanctions against) Russia will inherently be an attractive location for Russia to use for sourcing sanctioned goods. 

6. The client asks you to ship goods to a country which would not normally import that product. For example, advanced microelectronic components being sent to a country which does not have a corresponding domestic industry. 

7. The shipper requests a specific route which does not align with normal practice, especially if this would incur additional time, expense, or includes transit via specific countries.  

8. The shipper requests that you transport the shipment for the majority of its planned route, but asks you to hand the shipment over to a local logistics firm for the final phase of the journey (instead of employing you to deliver the shipment directly to the named consignee). 

9. The consignee’s delivery address is anomalous, or inappropriate to receive the type of good in question. For example, a consignment of heavy equipment being delivered to an office block, or being provided with a residential address when you would normally expect to deliver to a commercial facility. A procurement or transhipment entity may use a residence (such as a private garage) or rented storage unit to receive shipments. 

2.3 Customer 

Pre-screening, contracts of carriage, transaction paperwork 

1. You receive an unsolicited approach from an overseas entity to ship goods from the UK, and you are unable to verify their identity or key information pertaining to them through independent research. 

2. The shipper or their nominated representative uses webmail instead of a corporate domain-based email account. 

3. The transaction involves multiple parties based in third countries, without a clear rationale. A procurement entity may attempt to use a shell company as a purchasing front. Further information on conducting background checks on potential customers, and screening tools to facilitate this process, can be found in our circumvention guidance for businesses.  

4. Last-minute changes to parties involved in the transaction from an entity in Russia or Belarus to an entity in another country. 

2.4 Transaction 

Pre-screening, contracts of carriage, transaction paperwork 

1. You are presented with false, inaccurate, or incomplete documentation, or the information provided is unusually vague when compared to normal procedure. 

2. You notice inconsistencies in the information provided across documentation associated with the consignment. In particular, the recipient on transport documentation may be different from the commercial invoice or customs declaration.  

3. Any indications or suspicion of attempts to record goods under a false Harmonised System (HS) code not subject to sanctions or export controls. 

4. The description of the goods in documentation associated with the consignment is non-specific or otherwise misleading. 

5. Any request from the client that you enter information into transaction documents which you know to be incorrect or unnecessarily vague. 

6. Documentation is presented in Russian, or the language used otherwise is not consistent with the stated destination. 

7. Your client is willing to pay significantly above the known market rate compared to the standard shipping process for the product and destination country, potentially due to taking an unnecessarily complex or circuitous transit route.  

8. Dividing the consignment and associated invoices into smaller shipments to remain under export control limits or value thresholds (excluding the standard use of ‘just in time’ shipping practices). A procurement entity may attempt to have goods split into smaller parcels and shipped in intervals to avoid detection. The entity may intend to consolidate the shipments later in a third country, before shipping to a sanctioned country or entity. Noting that transactions should be considered in context, reviewing your records over a period of time may help to show small, recurring consignments for similar goods being shipped along similar routes by the same or connected entities.  

9. Requests to use a non-standard payment route. For example, outside of SWIFT, via smaller overseas banks, by cash, or via cryptocurrency. 

10. Payment for your services unexpectedly comes from a third country, business, or bank account which is not listed in relevant documentation or otherwise involved in the transaction. Any entities on wire instructions or payments that were not identified in the original documentation are suspect. 

11. Any other indications or suspicion that documentation (or material particulars therein) may be fraudulent. If something doesn’t feel right, consider conducting further checks before proceeding with the transaction. 

3. Postal and express operators 

Postal and express operators should be especially mindful of the risk that the contents of consignments may be falsely declared to avoid detection. Many of the sanctioned components sought by Russia can be packaged in smaller consignments and declared at a value under customs thresholds. Those seeking to evade sanctions may attempt to take advantage of simplified customs processes, including bulk declarations. 

Insofar as this is possible within the context of your business model, consider prioritising checks for shipments in the following circumstances: 

• shipments containing electronic goods, especially microelectronics, communication devices, drones/drone parts, power tools, other mechanical components or devices 

• shipments with vague or dubious descriptions of the contents (for example, ‘spare parts’, ‘samples’, among others) 

• if the consignment is marked as a ‘gift’ for customs purposes, but the nature of the goods or other aspects of the consignment, the shipper, or the delivery address suggest the shipment may be commercial  

• if there are any other indications that the nature or value of the goods may have been falsely declared 

Agree and publish a ‘sanctioned goods policy’, for both internal and public use. The policy should make clear that the export of sanctioned goods to Russia, Belarus, and other sanctioned destinations is prohibited, and that your company is taking steps (for instance, spot checks) to tackle the circumvention of sanctions via third countries. 

Consider adding sanctions-specific clauses to your terms and conditions and any contracts of carriage. See section 1.1 of this guidance or the ‘no Russia’ clause guidance.  

Monitor transactional data over time, to the extent this is possible within your business model. Look for trading patterns or customer behaviours which could indicate attempts to keep shipments under value thresholds to avoid triggering a customs inspection, for example, specific customers frequently sending the same/similar items in small quantities, either in quick succession or at regular intervals, to the same (or similar) delivery address(es).  

Very few goods are now permitted for export to Russia and Belarus. Consider implementing checks on all consignments to Russia and Belarus to ensure that sanctioned goods are not being smuggled under false descriptions. 

4. Goods sanctioned for import into the UK 

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. See more information on import sanctions.  

Companies should undertake checks to ensure that they are not facilitating the import of prohibited goods, and that, where applicable, licences, records, or supply chain documentation are made available for any exemptions to these prohibitions. 

5. Enforcement and reporting 

If you breach trade sanctions, you may face enforcement action, which could include criminal prosecution or a civil monetary penalty. 

How you make a report will depend on which trade sanctions measures you think have been breached, as you’ll need to report them to the correct organisation. See more information on reporting a suspected breach. 

HMRC and the Office of Trade Sanctions Implementation (OTSI) within the Department for Business and Trade work together to enforce breaches of trade sanctions. 

HMRC is responsible for enforcing trade sanctions on goods crossing the UK border in line with its role as the UK’s customs authority. As part of its customs role, HMRC is also responsible for measures relating to strategic exports (military and dual-use goods and technology) and the provision or procurement of services that are ancillary to the import or export of goods. 

OTSI is responsible for: 

• sanctioned services that are not ancillary to the movement of goods 

• the movement of sanctioned goods, technology and ancillary services outside the UK, where a UK person is involved 

If you have any indication that sanctioned goods may have been supplied or diverted to Russia from the UK, please email exports.strategic@hmrc.gov.uk. If you discover any attempt to import or export goods or transfer controlled technology without an appropriate export licence in place, it is very important to consider reporting the irregularity to HMRC as soon as possible. Details for making a disclosure can be found on the Export controls: military goods, software and technology page. 

If you suspect that you, or someone else, has breached trade sanctions within OTSI’s remit, you should report it to OTSI as soon as possible using the online service: Report a suspected breach of trade sanctions.  

Workers and ex-workers can make a whistleblowing report to OTSI about a person or business they think has committed a breach of trade sanctions enforced by OTSI.  See more information on whistleblowing for trade sanctions. 

Guidance on OTSI’s enforcement approach can also be found on its website. For all other enquiries, you can use the OTSI contact form. 

To receive email notifications of changes to sanctions lists and legislation and newly published guidance resources, sign up to get UK sanctions email alerts. 

6. Additional resources 

Please note that the UK government is not responsible for the contents of any external resources or screening tools indicated here. Companies’ usage of these tools is at their own discretion. 

6.1 UK government resources 

• Collection: UK sanctions 

• The Russia (Sanctions) (EU Exit) Regulations 2019 

• Russia sanctions statutory guidance 

• Common High Priority Items List 

• UK Sanctions List 

• Countering Russian sanctions evasion – guidance for businesses 

• Guidance on preventing Russian evasion of export controls and sanctions produced by the G7 

• Russia sanctions: sales of oil tankers to third countries - GOV.UK 

• Starter guide to UK sanctions - GOV.UK 

6.2 International partners 

• European Commission Directorate-General for Financial Stability, Financial Services and Capital Markets Union, counter-circumvention guidance 

• European Commission guidance for EU operators: implementing enhanced due diligence to shield against Russia sanctions circumvention 

• U.S. Bureau of Industry and Security know your customer guidance 

• U.S. Bureau of Industry and Security circumvention red flag indicators 

• U.S. Bureau of Industry and Security addressing export diversion risks guidance 

• U.S. Department of Commerce Consolidated Screening List 

• U.S. Department of Commerce, Department of the Treasury, Department of Justice, Department of State, and Department of Homeland Security quint-seal compliance note (know your cargo)