Incoterm EXW & Sanctions: Guide + Download
- Arne Mielken
- Jun 11
- 3 min read
EXW doesn’t shield exporters from sanctions liability—find out why and how to stay compliant. + Download the EU's Guide on Ex Works & Sanctions
If you’re an exporter or compliance officer dealing with sanctions, export controls, or trade compliance, you’ve likely encountered the EXW (Ex Works) Incoterm. On paper, it seems straightforward—shift all responsibilities to the buyer. But here's the reality: private contracts don’t override sanctions law. As the EU tightens enforcement around countries like Russia, Iran, and North Korea, understanding how Incoterms intersect with sanctions compliance isn’t just useful—it’s critical.
Key Questions Covered in This Blog
What are Incoterms, and what does EXW mean for exporters?
Does EXW shift all responsibility to the buyer under EU law?
Can a seller use Incoterms to avoid liability under EU sanctions?
What due diligence is expected under EU sanctions law?
What are the penalties for breaching sanctions, even when using EXW?
"Even under EXW, you carry the weight of sanctions on your shoulders. You can delegate delivery—but never your compliance."Arne Mielken, Managing Director, Customs Manager Ltd
Abbreviations Used In This Blog
EXW: Ex Works (Incoterms rule)
EU: European Union
OFSI: Office of Financial Sanctions Implementation (UK)
OFAC: Office of Foreign Assets Control (USA)
What are Incoterms, and what does EXW mean for exporters?
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