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Russia, Crimea and Belarus trade sanctions

Following events in Ukraine, the UK Government has imposed further trade sanctions on Russia including export and import restrictions and bans on certain categories of goods and services.

If you are considering importing or exporting goods or technology involving Russia, Crimea and Belarus – we strongly recommend that you first consult with importexporthub@admin.cam.ac.uk and the Export controls team (in the Research Office) at researchgovernance@admin.cam.ac.uk to consider if there are prohibitions in place and licencing requirements. There are severe penalties for persons that do not comply.

The sanctions include bans and restrictions on:

  • the import of Russian origin iron and steel, as of 30 September 2023;
  • certain other imports (arms and related materials) originating in Russia (even if the immediate place the goods were shipped from was not Russia);
  • the export to Russia of military goods, military technology, and dual-use technology;
  • the provision of technical assistance that enables or facilitates the conduct of certain military activity;
  • the export to Russia of certain goods and technology for use in the energy sector, particularly for off-shore drilling and exploration;
  • the export to Russia of certain 'critical industry' goods and technology and aviation and space goods and technology;
  • the export to Russia and Crimea of infrastructure-related exports;
  • all imports originating in Crimea; and
  • supply and delivery prohibitions – affecting freight agents / carriers ability to deliver goods.
New UK sanctions on imports of iron and steel originating in Russia

From 30 September 2023, the import of Russian origin iron & steel into the UK is now prohibited. The UK has introduced new Russian trade sanctions banning the import of certain iron and steel products that incorporate iron or steel inputs originating in Russia and undergo processing in other ‘third’ countries. UK importers have to be able to provide evidence that imports of such products did not originate in Russia. 

Goods in scope
The iron and steel products in scope for prohibition have been outlined in HMRC guidance and fall within commodity code chapter headings 72 and 73.  This includes raw materials and semi-finished products such as nuts, bolts, tubing, iron & steel wool & stainless steel containers.

An example of goods that are now prohibited are steel slabs which are exported from Russia to China and processed into hot rolled coils of alloy steel, taking on Chinese origin in the process. Or stainless steel ingots which are imported in China to make sinks, also taking on Chinese origin.

Evidential requirements
The UK guidance states that traders are expected to carry out due diligence on the origin of products and may be requested to present evidence of the supply chain of goods at the border. Evidence requested to be provided through documentation could include:

  • the country of origin of the iron and steel products processed in the third country(s) after the fact
  • the date that the iron and steel product left its country of origin
  • the country(s) and facility(s) where processing has taken place

An example of evidence may include, but is not limited to, a Mill Test Certificate (MTC), where the relevant information cannot be summarised in a single document.

Action required by Departments

Departments need to be aware of this extension to sanctions rules and, where Departments plan to purchase steel or iron goods (that haven’t been integrated into a larger system), Departments should obtain the 10 digit commodity code and complete due diligence with suppliers before placing the order.  If due diligence is not completed, there is the risk of Customs refusing to release the goods if they are selected for review and of breaching sanctions rules, which could constitute one of a number of criminal offences.

What are ‘dual-use’ goods and technology?

Dual-use items (including physical goods, software, and technology) are those which can be used for both civil and military purposes. The UK maintains a list of dual-use goods and technology that it considers to be 'export controlled'. All researchers exporting to Russia or working with Russian collaborators are advised to consider whether their export is included on this list and take advice from the contacts below. Exports to Russia are likely to be prohibited unless the export meets one of a number of exemptions. 

Examples of dual-use goods and technology include global positioning satellites, night vision technology, thermal imaging, some lasers, some drones and other goods that are designed using precise manufacturing specifications to be used in or in conjunction with dual-use/military equipment. Other examples may include chemicals and radioactive material. In addition, there are wider controls on exports for use, in any way, in nuclear or weapons of mass destruction programmes. 

What are 'critical industry' goods and technology?

The new sanctions create an additional list of goods, software and technology that are controlled for export to Russia. These include a number of specific: electronic devices; computers; software; telecommunications equipment; information security technology; sensors and lasers; navigation and avionics equipment; marine vessels, equipment and software; and aviation, space and propulsion goods and technologies. All researchers/staff exporting to Russia or working with Russian collaborators in any of the areas above should take advice from the contacts below. As for dual-use goods and technology, exports of these equipment are likely to be prohibited unless an exemption applies.

Belarus

There are also sanctions relating to certain individuals and companies from Belarus, alongside existing sanctions.

Further information and support

For further guidance: https://www.research-operations.admin.cam.ac.uk/policies/export-control/further-guidance.  If you have any questions, please contact importexporthub@admin.cam.ac.uk and researchgovernance@admin.cam.ac.uk.  Further updates will be provided as the situation changes.

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