In 2026, sanctions risk is no longer limited to a direct match against a sanctions list. The practical issue is whether the entire transaction can be lawfully performed — including the counterparties, goods or services, route, payment, end user, technology and dispute forum.
1. Separate the two layers of risk
Russian measures and foreign sanctions regimes can both affect a transaction. The relevant jurisdiction, bank, technology, goods, carrier or rights holder should be identified before execution.
2. Screen counterparties beyond the name
Check the legal entity, management, ownership and control chain, as well as banks, currency, manufacturer, seller, end user and the countries of production, transit and use.
3. A third country is not an automatic solution
Changing the route may be lawful, but only when the new route and intermediary have a real economic function and the restrictions of each relevant jurisdiction remain satisfied.
4. Build sanctions protection into the contract
Consider representations, notification duties, lawful alternative performance, suspension rights, termination and evidence requirements for sanctions-related disruption.
5. Review the payment separately
A permitted product can still face payment problems. Agree the bank, currency, payment route, compliance documents and contingency plan before the shipment or service is committed.
6. Document the rationale
A defensible file should record who was screened, when, against which sources, what conclusion was reached and who approved the transaction.
7. Watch the red flags
Opaque intermediaries, unexplained end-user changes, inconsistent goods descriptions, requests to disguise the payment purpose and purely paper-based route changes require enhanced review.
8. Build a 30-day compliance routine
Map key counterparties and routes, introduce risk levels, refresh contract clauses, create transaction files, prepare lawful alternatives and review each foreign jurisdiction separately.
This article is informational and reflects the legal position as of 6 October 2026. Sanctions, export, currency and corporate restrictions change frequently and must be checked for the specific transaction and date.