Navigating EU sanctions: common compliance pitfalls

Frederik van Essen
Frederik van Essen
Senior Legal & Compliance Expert, EU Sanctions Helpdesk
Published 03 Nov 2025

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This recording of the "EU Sanctions: Common Compliance Pitfalls" workshop, organised by the Lithuanian Union of Customs Practitioners Association (LCPA) with the EU Sanctions Helpdesk, is relevant to customs and export-control professionals who need to identify, screen for, and manage EU restrictive measures in day-to-day trade.

Topics covered:

  • What EU sanctions ("EU restrictive measures") are, who they can target, and the main categories: asset freezes, trade restrictions (export and import bans), financial restrictions, and other restrictions
  • Export prohibitions on military, dual-use, maritime, luxury and oil-and-gas-associated goods, including bans on related services (technical assistance, brokering, financing)
  • Import restrictions, illustrated with the ban on Russian-origin iron and steel
  • The role, services, and limits of the EU Sanctions Helpdesk, including how to submit a compliance question and what its reports can and cannot be used for
  • A case study on the transit of luxury goods through Russia to a third country
  • A case study on screening a Hong Kong supplier after a change in ownership structure linked to a sanctioned Russian national
  • Common compliance pitfalls: concealed end users, controls that miss spare parts or related services, and assuming another party will handle sanctions screening
  • Audience Q&A on education/research exemptions, circumvention red flags via third countries, finding sanctioned HS/CN codes, and the legal basis for refusing a shipment

For a broader overview of the topic, please watch the full recording. The slides are available in the Resources section.

Please note that this summary was generated using AI, based on the recording and available slides.

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