UK Guidance on Countering Sanctions Evasion – Freight and Shipping

On 3 November 2025, the UK published guidance for freight, shipping and logistics providers on countering Russian sanctions evasion. The guidance was issued by HM Government to assist firms in identifying and managing sanctions-related risks in cargo movements, vessel deployment, freight forwarding and customs-linked processes.

The guidance highlights:

• Core due-diligence expectations, including “know your customer, know your cargo,” verification of beneficial ownership, validation of origin and end-destination, screening against UK sanctions designations, and documentation consistency checks.

• A list of red-flag indicators, including opaque routing, unusual trans-shipment behaviour, unexplained changes in cargo documentation, use of shell or nominee entities, third-country intermediaries with limited transparency, and high-risk or dual-use goods movements.

• Responsibilities for freight, brokers, hauliers, carriers, port agents and logistics intermediaries, stressing that negligence or failure to conduct adequate due diligence may create sanctions-compliance exposure under UK law.

The guidance clarifies that sanctions-evasion typologies increasingly operate through routine commercial channels — shipping, freight forwarding, cross-border express movements, and trade finance. Firms engaged in these activities are advised to adopt risk-based controls, escalate unusual activity for review, and document diligence actions to support regulatory expectations.


The guidance underscores a move toward behavioural and supply-chain scrutiny, not solely counterparty screening. The maritime value chain is expected to operate structured due-diligence processes, monitor for red flags, maintain provenance documentation and understand beneficial ownership throughout the logistics chain. Sanctions compliance is a core operational concern for commercial logistics, not only for banks and regulated financial entities.

A link to the guidance can be found here.