The European Commission published “Guidance for EU operators: implementing enhanced due diligence to shield against Russia sanctions circumvention” (“Guidance”) on 7 September with the stated intent of providing a general overview of due diligence expectations around preventing the circumvention of Russia sanctions.
Like its counterparts in the US and UK, the EU is relying on industry to be the first line of sanctions defense by improving related due diligence programs and enhancing their abilit...
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