No-Russia clause: System-supported regulatory compliance assurance

Integrating EU sanctions regulations into your SAP system landscape

Legal requirements

Legal background of the No-Russia clause

Article 12g of Regulat ion (EU) No 833/2014

https://eur-lex.europa.eu/eli/reg/2014/833/oj/?locale=de

The so-called „no-Russia clause“ is a contractual obligation under EU sanctions law designed to prevent the direct or indirect re-export of certain goods and technologies to Russia. It is specifically regulated in Article 12g of Regulation (EU) No 833/2014 in the context of the Russia sanctions.

  • Binding EU sanctions rules

  • Prevention of circumvention

  • Obligation to provide proof to authorities

When does the obligation apply?

  • The requirement for a „no-Russia“ clause does not apply to all products across the board.

  • This concerns specific categories of goods listed in the annexes to Regulation (EU) 833/2014.

Regulatory framework

Requirements for an effective compliance system

To comply with the No-Russia clause and other sanctions regulations, a robust and automated system is essential.

Automated checks

Continuous real-time monitoring of business partners and sanctions lists for proactive risk avoidance.

Risk-based assessment

Intelligent analysis and classification of countries and re-export routes to identify potential circumvention attempts early on.

Immediate transaction blocks

Automatic blocking of transactions upon detection of risk matches to immediately prevent compliance violations.

Audit-proof documentation
Complete audit trail and tamper-proof recording of all audits and decisions for regulatory compliance.
 
Compliance Risiken

Liability and business risks

Failure to comply with the No-Russia clause can have far-reaching legal and economic consequences for your company.

High fines and penalties

Severe financial penalties and criminal prosecution for violations.

Liability of organs

Personal liability of management and other bodies in the event of an inadequate compliance system.

Reputation and market risks

Damage to the company’s image, loss of trust among customers and partners, and a negative impact on market value.

Exclusion of orders

Loss of eligibility to participate in public tenders and restrictions on private business relationships.

Legal requirements

Business requirements

Verifiable controls

Complete documentation of all test steps

Clear responsibilities

Defined roles and approval processes

Audit compliance

Auditable documentation for authorities and auditors

SAP solution

System-supported implementation in the SAP system

Automated compliance processes without media breaks

SAP solution

Technical implementation in SAP

1. Customer base identification

Automatic marking of risk-relevant business partners

2. Order verification

System-side validation during order creation and modification

3. Locking & unlocking mechanisms

Automatic blocking based on risk indicators, manual approval by compliance

4. Complete documentation

Audit-proof logging of all audits and decisions

Our range

Process review and implementation

We offer you a comprehensive review of your existing processes and support you in the full implementation of the No-Russia clause.

After the process review, we calculate the specific effort required for your company and propose a customized approach. Based on experience and depending on the company size, the effort for implementation is approximately 8 consulting days.

1. Process analysis

Review of your current sales processes and compliance requirements

2. Effort estimation

Detailed calculation based on your system landscape

3. Solution concept

Individual proposal for optimal implementation

4. Implementation

Support with the technical implementation in SAP

Shaping the future together

Lars Bock

Head of Business Consulting

Claudia Schaumburg

Board Bitech AG

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