In view of the recent events Russia has strengthened control in sphere of foreign trade with Turkey.

Below you will find an overview of effective measures as well as possible sanctions to be introduced.

1. Customs control

According to confidential information, the Federal Customs Service has distributed among Russian customs authorities risk profiles in respect of goods delivered from Turkey and goods originating from Turkey. Practically, 100% of such goods are to be controlled by the customs authorities.

The following additional control measures are applied:

  • customs examination of 100% of the goods;
  • visual inspection/weighing/customs control with a mobile inspection complex;
  • sample collection;
  • expert review of goods;
  • confirmation of the declared customs value.

In addition, the customs authorities require original certificates of origin and will carry out an expert review of these documents.

As the customs control of the declared customs value and classification code is being exercised, the goods are released subject to security of payment of customs duties and taxes.

2. Other control measures

The Federal Service on Surveillance for Consumer Rights Protection and Welfare ("Rospotrebnadzor") has classified clothes (including baby clothes) and household chemicals originating from Turkey as "high risk" products. The Federal Service for Veterinary and Phytosanitary Surveillance ("Rosselkhoznadzor") has strengthened control over food products originating from Turkey.

The claims of Rospotrebnadzor and Rosselkhoznadzor are based on the non-compliance of goods with the Russian safety and quality regulations.

3. Possible economic sanctions

Federal Law No. 281-FZ dated 30 December 2006 " On Special Economic Measures" allows the imposition of special economic measures in response to an internationally wrongful act or un-friendly actions of a foreign state or its agencies and officials.

On 28 November 2015 Vladimir Putin signed the Decree " On the Measures to Ensure Homeland Security of the Russian Federation and Protection of Russian Citizens Against Abusive and Other Illegal Actions and on Applying Special Economic Measures Against the Republic of Turkey".

The measures provided by the Decree include:

  • Banning cross-border transactions involving those products originating from Turkey that are specified in the list (the list is to be approved by the Government).
  • Banning operations of some Turkish organisations (the list is to be approved by the Government).
  • Banning employment of Turkish employees from 1 January 2016 (save for the employers from the list approved by the Government).
  • Suspending visa-free entry from 1 January 2016.
  • Recommending tourist agencies to avoid sending tourists to Turkey.
  • Banning charters.

Some additional steps can be taken at the subordinate legislation level. Thus, these matters should be carefully monitored.

If there are any questions related to shipments to the Russian Federation through Turkey, it is necessary to analyze restructuring logistics channels, including using the opportunities provided by the Customs Union, however the risks should be carefully considered as the matter is not unambiguous.