Guidance on countering Russia evasion (Australia, Canada, New Zealand, United Kingdom, United States)

High-priority items critical to Russian weapons systems

High-priority items critical to Russian weapons systems

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

According to a release [PDF 300 KB] (September 26, 2023) from the Bureau of Industry and Security (BIS) of the U.S. Department of Commerce, the guidance provides:

  • The list of 45 prioritized Harmonized System (HS) codes containing items Russia needs for its weapons systems, of which nine codes are the highest priority
  • Irregular patterns associated with importers in countries outside of the Global Export Control Coalition (GECC)—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
  • 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

Read the full guidance as posted on the BIS website.

 

For more information, contact a professional with KPMG’s Trade & Customs services:

Doug Zuvich
Partner and Global Practice Leader
E: dzuvich@kpmg.com

John L. McLoughlin
Principal and East Coast Leader
E: jlmcloughlin@kpmg.com

Andy Siciliano
Partner and National Practice Leader
E: asiciliano@kpmg.com

Steve Brotherton
Principal and Global Export and Sanctions Leader
E: sbrotherton@kpmg.com

Luis (Lou) Abad
Principal, Washington National Tax
E: labad@kpmg.com

Irina Vaysfeld
Principal
E: ivaysfeld@kpmg.com

Amie Ahanchian
Principal
E: aahanchian@kpmg.com

Christopher Young
Principal
E: christopheryoung@kpmg.com

Gisele Belotto
Principal
E: gbelotto@kpmg.com

George Zaharatos
Principal
E: gzaharatos@kpmg.com

Andy Doornaert
Managing Director
E: adoornaert@kpmg.com

Jessica Libby
Principal
E: jlibby@kpmg.com
John Anderson
Managing Director
E: johneanderson@kpmg.com
Jenna Leigh Glass
Managing Director
E: jennaleighglass@kpmg.com

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