Trade compliance is key
If you trade in the global marketplace, it’s important to be sure that your shipments are in compliance. Because breach of sanctions is a criminal offense, we wanted to create awareness of this issue before any problems arise. In terms of the products and services that UNICOM Engineering deals with specifically, we believe that our customers should remain unaffected. What the sanctions are specifically saying is this:
- Dual-use items to military end-users in Russia are prohibited.
- In addition, spare parts for military use items or military end-users are prohibited.
- Dual-use, as defined by the EU in Annex 1 of EC regulation Number 428/2009, states that “This prohibition should not affect the exports of dual-use goods and technology, destined/designated for non-military use or for a non-military end-user.
In the interest of export compliance, it is strongly suggested that shipments of dual-use and non-dual use items be separated. As other countries strive for trade compliance, delays in the shipment of dual-use parts should be expected. For example, Dutch Customs has announced that all requests for export document approval for shipments containing dual parts will be held. These requests will be forwarded to the Central Service of Import and Export in the Netherlands, and that organization will determine on a case-by-case basis whether or not to issue export documents. As you can imagine, this will result in delays.
These measures taken by the EU are at the forefront of international efforts toward non-proliferation and must adjust as security risks and threats evolve. Regularly holding public consultations and maintaining a constant dialogue with industry associations as well as academia and civil society, the European Commission strives to strike a balance between security and competitiveness. You can read the EU’s press release regarding these sanctions here.
UNICOM Engineering will continue to ensure compliance of sanctions and will inform clients of any delays caused by this issue.
Our Global Logistics Services team is fully versed in global trade regulations, and we’re ready to help clients in every way possible. To learn more about UNICOM Engineering’s Trade Compliance capabilities visit our website and connect with us on LinkedIn, Facebook, and Twitter.
UNICOM Engineering will also be at ASIS 2014 from September 29th – October 3rd.