Published on 3 November 2025, the document – Countering Russian sanctions evasion: guidance for the freight and shipping sector – sets out due-diligence practices, red-flag indicators and reporting duties for hauliers, freight forwarders, customs intermediaries and postal operators.
Although aimed at UK-based companies, the advice closely mirrors actions taken within the European Union and G7 to stop the flow of restricted goods to Russia. For many operators working across borders, the recommendations provide useful insight into what enforcement authorities are likely to look for.
Freight operators seen as the first line of defence
Freight and shipping companies are described as a “crucial service” in efforts to limit Russia’s access to sanctioned goods. Transport operators are often among the first to notice unusual consignments, incomplete paperwork or suspicious routing.
Authorities on both sides of the Channel warn that due diligence is not a formality. Firms that participate in or ignore sanctions breaches can face criminal prosecution or heavy fines. Simply checking third-party databases is not enough — companies must demonstrate that they have applied their own controls and risk assessments.
Strengthening compliance: know your customer, know your cargo
The guidance urges logistics providers to verify the identities of shippers and consignees, check names against sanctions lists and review long-term partnerships for new risks.
Businesses are encouraged to include “no re-export to Russia” clauses in contracts of carriage and to request written confirmation that clients have completed their own sanctions checks.
When handling cargo, operators should watch for vague product descriptions such as “spare parts” or “samples,” mismatched commodity codes, labels in Cyrillic, or discrepancies between declared weight and contents. Each can signal an attempt to disguise the true nature or destination of the shipment.
Red-flag routes and suspicious transactions
The UK document lists a range of red-flag indicators that may point to circumvention attempts — many of which echo European Commission guidance. These include:
- shipments routed through third countries bordering Russia;
- long or costly detours from normal trade routes;
- last-minute changes to consignees or intermediaries; and
- consignments divided into smaller parcels to stay below customs thresholds.
Financial clues can also reveal risk. Over-market freight rates, cryptocurrency or cash payments, and transactions funded from unrelated third-country accounts all warrant closer scrutiny.
Small parcels under the microscope
Postal and express operators are warned that dual-use goods, including microelectronics and drone components, are often shipped as low-value “gifts.”
The government suggests adopting a sanctioned-goods policy, running spot checks and analysing data for patterns of repeated small-value shipments to the same destinations — a practice already encouraged by customs authorities in Germany, Poland and the Netherlands, where enforcement has intensified.
Enforcement and cooperation across borders
In the UK, trade-sanctions enforcement is shared between HM Revenue & Customs (HMRC) and the Office of Trade Sanctions Implementation (OTSI). Within the EU, comparable responsibilities lie with national customs agencies and the European Anti-Fraud Office (OLAF).
Both sides promote whistleblowing channels for employees who suspect breaches, and both stress the importance of reporting any irregularities promptly. The move underlines a coordinated Western push to make the logistics industry an active partner in sanctions enforcement.
A message for Europe’s freight industry
While the guidance is British in origin, its message is European in scope: transport operators now form part of the frontline in enforcing sanctions policy.
For hauliers, forwarders and brokers moving goods between the UK and EU, understanding these expectations can help prevent costly delays or investigations. For companies trading wholly within the EU, the same principles — verify partners, scrutinise cargo, and question red-flag consignments — remain equally relevant.
The full document, Countering Russian sanctions evasion: guidance for the freight and shipping sector, is available on GOV.UK.
Key takeaways for European hauliers and forwarders
- Cross-border relevance: the UK guidance complements EU and G7 crackdowns on sanctions circumvention.
- Due-diligence focus: verify shippers, consignees and cargo descriptions — don’t rely solely on automated databases.
- Spot the red flags: complex routes, vague paperwork, or unusual payments may indicate diversion.
- Small parcels matter: dual-use components are often disguised as low-value goods.
- Shared enforcement: UK agencies (HMRC/OTSI) and EU bodies (OLAF/customs) pursue parallel investigations.
- Operational lesson: compliance is now an everyday part of freight management, not a box-ticking exercise.
