EU Sanctions Enhancement: Guidelines on “no re-export to Russia” clauses for the compliance and enforcement of sanctions

February 2024
Region: Europe

The European Commission has issued updated guidance on a requirement that will soon oblige European Union (“EU”) exporters to include clauses in their contracts banning the re-export of certain sensitive products to Russia. This requirement falls under the existing prohibition contained in Article 12 of Council Regulation (EU) No 833/2014 (the “Regulations”) on knowingly and intentionally engaging in activities designed to circumvent sanctioning laws.