Released on 3 November 2025, the document, Countering Russian sanctions evasion: guidance for the freight and shipping sector, is aimed at hauliers, freight forwarders, customs intermediaries, and postal operators, setting out due-diligence practices, red-flag indicators, and reporting obligations.
The guidance describes freight and shipping operators as a “crucial service” in the effort to reduce Russia’s capacity to sustain its war in Ukraine.
According to the document, businesses moving goods are often the first to spot attempts to conceal the true destination or nature of shipments.
The government stresses that due diligence is not a formality. UK companies can face criminal prosecution or civil penalties if they participate in or facilitate trade that circumvents sanctions. Using third-party screening tools alone is not a defence, each firm must assess its own exposure and implement effective internal controls.
Strengthening compliance: “Know your customer, know your cargo”
Logistics operators are advised to verify the identities of shippers and consignees, cross-check names against the UK Sanctions List, and repeat checks periodically — even for long-standing partners. Changes in company ownership, management, or trading patterns may indicate a shift in risk.
The government also recommends including “no re-export to Russia” clauses in contracts of carriage and obtaining written confirmation from shippers that they have carried out their own sanctions risk assessments.
On the cargo side, companies should check all paperwork for inconsistencies or vague descriptions such as “samples” or “spare parts.” Labels written in Cyrillic despite a non-Russian destination, mismatched commodity codes, or discrepancies between the weight and declared contents are cited as warning signs.
Red-flag routes and suspicious transactions
The document highlights a range of red-flag indicators that could signal an attempt to circumvent sanctions.
Among them:
- shipments routed through countries bordering Russia or with weak export-control systems;
- unusually long or costly delivery routes;
- sudden substitution of the consignee or intermediary company; and
- consignments broken into smaller shipments to avoid inspection thresholds.
Payment behaviour can also reveal risk. Over-market freight rates, payments from unrelated third-country accounts, or requests to use cryptocurrency or cash are all listed as potential red flags.
Small parcels, big risks: warning to postal and express operators
Postal and express carriers are singled out for attention. The guidance notes that microelectronics, drone components, and other dual-use items can be hidden in small parcels falsely declared as “gifts” or low-value goods.
Operators are urged to create a sanctioned-goods policy, carry out random spot checks, and monitor shipping data over time to detect repeated small-value consignments headed to the same destination.
The government reminds businesses that very few goods are now permitted for export to Russia or Belarus — and that sanctions may also apply to goods processed through third countries.
Enforcement: who investigates breaches and how to report them
The document clarifies the division of enforcement responsibilities:
- HM Revenue & Customs (HMRC) oversees goods crossing the UK border and enforces export-control regulations.
- The Office of Trade Sanctions Implementation (OTSI) within the Department for Business and Trade handles sanctions breaches involving services or overseas transactions by UK entities.
Companies that suspect a breach are urged to report it immediately — to HMRC for goods, or to OTSI for services and other non-border cases.
Current and former employees can also submit whistleblowing reports if they believe sanctions rules are being violated.
Beyond Russia: broader lessons for global trade
Although the guidance focuses on Russia, it notes that much of the advice applies to other sanctioned countries, including Belarus, Iran and North Korea.
The UK Government frames the initiative as part of its broader effort to close “loopholes” in international trade routes and prevent the diversion of sensitive technologies.
For the road freight sector, the message is clear: sanctions compliance must now form part of day-to-day logistics management, from verifying customers to cross-checking packing lists and inspecting shipments.
The full guidance, Countering Russian sanctions evasion: guidance for the freight and shipping sector, can be accessed on GOV.UK.
Key takeaways for hauliers and forwarders
- Stay alert to circumvention tactics: watch for vague paperwork, odd routing, or sudden changes in consignees.
- Verify every partner: check shippers and consignees against the UK Sanctions List and re-screen periodically.
- Inspect cargo and documents: mismatched labels, HS codes, or Cyrillic packaging on non-Russian routes warrant follow-up.
- Include compliance clauses: add “no re-export to Russia” provisions in contracts of carriage.
- Be cautious with payments: third-party, cash, or cryptocurrency payments are potential red flags.
- Know where to report: suspected breaches should go to HMRC or OTSI, depending on the case.
