sanctions 28 September 2023

US and allies issue joint ‘priority items’ diversion guidance

The governments of Australia, Canada, New Zealand, the United Kingdom and the United States have issued joint guidance to industry and academia identifying high priority items critical to Russian weapons systems and urging specific actions to prevent diversion of these items to Russia through third countries.

The action was a follow-up to the establishment last June of the ‘Export Enforcement Five’ or ‘E5’ partnership to coordinate on export control enforcement issues.

The US Bureau of Industry and Security (‘BIS’) said, 26 September, that the guidance ‘provides industry and academia with the list of 45 prioritized Harmonized System (HS) codes containing items Russia needs for its weapons systems, of which nine (9) codes are the highest priority,’ and ‘then identifies anomalous patterns associated with importers in countries outside of the Global Export Control Coalition (GECC).’

It explained that the GECC is the 39-member global coalition ‘that has implemented substantially similar controls in response to Russia’s invasion of Ukraine, that may raise diversion concerns, due diligence tips for screening such parties, and red flag indicators that may be relevant to exporters to assist in determining whether an activity may be connected to export control and/or sanctions evasion.’

BIS said that since the Russian invasion of Ukraine in February last year, it has implemented stringent export controls restricting Russia’s access to the technologies and other items that it needs to sustain its war in Ukraine, targeting Moscow’s defence, aerospace, and maritime sectors, and expanded to its oil refining, industrial, and commercial sectors, as well as to luxury goods used by Russian elites.’ ‘BIS’s controls have also been applied to Belarus for its substantial enabling of Russia’s invasion and have been continually updated to align with GECC allies and partners, which include the E5,’ the statement said. https://mail.google.com/mail/u/1/#inbox/WhctKKZGgJwxZShNtCTgBJSgrvNNwgRRphfNbkxWtqjBHmddrLNjJNzGLmPNfzwfFKckfbG