EU exporters of high priority items must put a no re-export to Russia clause in their contracts, run due diligence on diversion risk and, if they own companies outside the EU, use best efforts to make them comply. Transit hubs such as the UAE, Turkey and Central Asia attract the most scrutiny from banks and customs. A short sanctions programme with classification, contracts, end-user statements and screening keeps shipments and bank accounts moving.
Sanctions are now an exporter's problem, not only Russia's
Four years after the first Russia packages, the EU has moved enforcement from Russia's border to the exporter's desk. A Dutch or Luxembourg company that sells electronics, machine parts or industrial goods to Dubai, Istanbul, Tbilisi or Almaty must now show that it took reasonable steps to stop those goods from reaching Russia. The question is no longer whether you sold to Russia, but whether you could have known.
Banks, customs and freight forwarders ask the same questions. Without a clause in the contract, an end-user statement and a screening record, a shipment can be held, a payment returned and a bank account closed, even if the goods never left the Gulf.
Article 12g
No re-export to Russia clause with remedies.
Article 12gb
Policies to spot diversion of high priority items.
Article 8a
Best efforts for non-EU subsidiaries.
Article 12f
Country-specific bans, first used in 2026.
What applies to an EU exporter in 2026
| Obligation | Who | What to do |
|---|---|---|
| No re-export to Russia clause (Art. 12g) | Sellers of common high priority items (Annex XL), firearms (Annex XXXV) and aviation goods to third countries | Clause in every contract, with remedies; keep proof |
| Due diligence on diversion (Art. 12gb) | Sellers of high priority items | Risk assessment, written policies, controls proportionate to size |
| Best efforts for subsidiaries (Art. 8a) | EU parents of non-EU companies | Group policy, screening, training, audit trail |
| Export bans (Annexes VII, XXIII and others) | Anyone selling to Russia, directly or indirectly | Classify goods by CN code; refuse indirect sales |
| Dual-use licences (Reg. 2021/821) | Exporters of dual-use items to any third country | Licence from the Dutch CDIU or the Luxembourg Office du contrôle des exportations |
| Reporting (Art. 6b of Reg. 269/2014, as clarified in 2026) | EU operators | Report suspected circumvention attempts to the competent authority |
Law and practice: Regulation 833/2014, Articles 8a, 12f, 12g and 12gb and Annexes VII, XXIII and XL; Regulation 269/2014; the 20th package of 23 April 2026 (Regulations 2026/506 and 2026/511) activated the anti-circumvention tool for the first time and listed entities in China, Turkey and the UAE. Directive 2024/1226 harmonised criminal penalties for sanctions violations; in the Netherlands breaches are offences under the Sanctions Act 1977 and the Economic Offences Act (WED). The European Commission's FAQs on the no re-export clause and on enhanced due diligence set out expected practice.
A sanctions programme that fits a trading company
- Classify your goodsCN codes of every product checked against Annexes VII, XXIII, XL and the dual-use list.
- Map customers and routesCountries, end users, freight forwarders and banks; flag transit hubs.
- Fix the contractsNo re-export clause, audit and termination rights, penalties, end-user statements.
- Screen and recordCustomers, owners, banks and vessels against EU, UN, UK and US lists; keep the evidence.
- Group policyRules for the UAE or other non-EU subsidiaries under Article 8a, with training.
- Bank and customs fileA short compliance memo that you can send to the bank or customs on request.
A Rotterdam B.V. sells CNC spare parts to a distributor in Sharjah. Three CN codes are on the high priority list. We add the Article 12g clause and an end-user statement to the framework contract, set up screening of the distributor's owners and banks, and draft a two-page compliance memo. The bank's periodic review closes in two weeks instead of three months, and a customs hold in Rotterdam is released after the memo is sent.
Sanctions risk check for your exports
The result updates with each answer.
Sanctions risk check for your exports
Answer six questions. You see your risk level, the obligations that apply and the documents a bank or customs officer will expect.
Every contract for high priority items.
End-user statements and screening records.
Best efforts for non-EU subsidiaries.
One document for bank and customs.
EU sanctions for exporters: frequent questions
What is the no re-export to Russia clause?
Since 20 March 2024 EU exporters selling common high priority items, firearms or aviation goods to a third country must contractually prohibit re-export to Russia or for use in Russia, with adequate remedies such as termination and penalties (Article 12g of Regulation 833/2014). Contracts concluded before 19 December 2023 had to be amended by 20 December 2024.
Do I need sanctions due diligence if I sell to Dubai, not Russia?
Yes, if your goods are sensitive. The UAE, Turkey, the Caucasus and Central Asia are named transit hubs. Article 12gb requires EU operators selling high priority items to third countries to have policies and controls to identify and mitigate the risk of diversion to Russia.
Is my UAE subsidiary bound by EU sanctions?
Not directly, but since the 14th package the EU parent must undertake its best efforts to ensure that companies it owns or controls outside the EU do not undermine the sanctions (Article 8a). In practice that means group-wide policies, screening and training.
What happens if a shipment is stopped?
Customs can hold goods for verification; the FIOD and the Public Prosecution Service investigate suspected breaches. In the Netherlands violations are economic offences, punishable with fines and imprisonment, and banks often terminate the relationship at the same time.
What is the anti-circumvention tool?
Article 12f allows the EU to restrict the sale of specific goods to a third country with a high risk of circumvention. It was used for the first time in the 20th package of April 2026, against Kyrgyzstan, for metal-working machining centres and data transmission equipment.