New guide offers tools to address sanctions in public procurement

The ProcurFinland Programme has published a guide to help contracting entities identify and prevent sanctions evasion and circumvention. The guide provides practical advice on taking sanctions into account at different stages of the procurement process. It lists warning signs that contracting entities can use to assess the risk of sanctions evasion and circumvention.

All procurements must be compliant with the sanctions imposed by the European Union or the United Nations. The violation of sanctions is criminalised in the Criminal Code of Finland. 

Contracting entities play a key role in enforcing sanctions and preventing sanctions evasion and circumvention. It is important that contracting entities recognise high-risk industries, suppliers and contracts and conduct sanctions checks of them with particular care.

The new guide describes the various types of sanctions and the national mechanism for freezing assets. It also provides practical advice on how to take sanctions into account at different stages of the procurement process. The enforcement of the extensive sanctions imposed on Russia are a particular focus of the guide.

The guide is available online in Finnish. It can be downloaded free of charge on the ProcurFinland website. The guide will be published later in Swedish and English. While not a legally binding document, it is guidance provided by experts.

The guide was drawn up by the Ministry of Finance and Ministry for Foreign Affairs as part of the ProcurFinland Programme for Effective Public Procurement. The Ministry for Foreign Affairs is the competent national authority for sanctions. It coordinates the national enforcement of sanctions and is responsible for granting authorisations.