Guidance for EU operators on implementing enhanced due dilligence to prevent circumvention of Russia sanctions

Basically, this Guidance recommends:

• Performance of a risk assessment to identify circumvention risks and implement mitigating measures which must be updated regularly.
• Enhanced due dilligence, consisting of: General good practice and best practice to address sanction circumvention typologies.
• Implementation of circumvention red flags within the general due dilligence.