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Sanctions on Fuel Products coming from Russian crude

As per January 2026, additional Measures are imposed related to the sanctions against Russia. This requires the inclusion of Additional References in the Customs declarations. We have automated processes to do our customs declarations.

  1. How can we avoid the interference of our automated processes? If you need to explain the functional requirements to a developer, how would you explain the functionality to work?
  2. It seems, given overall priorities, the development of any automated solution will not be ready in time. How would you manage any interim period to avoid non-compliance?
  3. Any other things to consider from risk and liability point of view?